This California Privacy Policy (“CCPA Policy”) describes how Inkvaan LLC (“Inkvaan,” the “Company,” “we,” or “us”) collects and processes personal information about our consumers who reside in California. The California Consumer Privacy Act (“CCPA”) requires us to provide our California consumers with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, sharing, and retention of their personal information, along with a description of the rights they have regarding their personal information. This Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy.

This CCPA Policy does not apply to our collection and use of personal information from residents outside of California. Consumers residing in other locations should see our general privacy policy at: Privacy policy.

Personal Information Collected

We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:

• Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
• Lawfully obtained, truthful information that is a matter of public concern.
• Deidentified or aggregated consumer information.

Personal Information Categories Chart

The chart below identifies the categories of personal information we collected from our consumers within the last 12 months.

Category	Examples	Collected
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.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (“California Customer Records”)	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. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law (“Protected Classes”)	Age (40 years or older), 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, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information).	NO
D. Commercial information	Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
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.	NO
F. Internet or other similar network activity	Activity on our websites, mobile apps, or other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites.	YES
G. Geolocation data	Physical location or movements, such as your zip code, the time and physical location related to use of our internet website or mobile application, or other information about your location or locations you visited.	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information, including customer service call monitoring and store video surveillance.	NO
I. Professional or employment-related information	Current or past job history.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g, 34 C.F.R. Part 99) (“FERPA 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.	NO
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES
L. Sensitive personal information	Further identified in the chart below.	YES

Sensitive Personal Information Categories Chart

Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer.

The chart below identifies which sensitive personal information categories, if any, we have collected from consumers to infer characteristics about them in the last 12 months.

Sensitive Personal Information Category	Collected to Infer Characteristics?
L.1. Government identifiers, such as your Social Security number (SSN), driver’s license, state identification card, or passport number.	NO
L.2. Complete account access credentials, such as usernames, account logins, account numbers, or card numbers combined with required access/security code or password.	YES
L.3. Precise geolocation, such as GPS data from a consumer’s mobile device that can provide its location in a geographic area, with an approximate radius of 1,850 feet.	YES
L.4. Racial or ethnic origin.	NO
L.5. Citizenship or immigration status.	NO
L.6. Religious or philosophical beliefs.	NO
L.7. Union membership.	NO
L.8. Mail, email, or text messages not directed to the Company.	NO
L.9. Genetic data.	NO
L.10. Neural Data, such as information generated by measuring a consumer’s central or peripheral nervous system’s activity that is not inferred from nonneural information.	NO
L.11. Unique identifying biometric information.	NO
L.12. Health information.	NO
L.13. Sex life or sexual orientation information.	NO
L.14. Children’s personal information (under age 16).	NO

Sources of Personal Information

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

• Directly from you, such as from the forms or other information you provide to the Company.
• Indirectly from you, such as from your interactions with the Company’s websites.
• From our service providers, such as order fulfillment and shipping providers, payment processing providers, and customer service support providers.

How We Use Personal Information

Personal Information Collection, Use, and Disclosure Purposes

We may use and disclose the personal information, including sensitive personal information, we collect to advance the Company’s business and commercial purposes, specifically to:

• Develop, offer, and provide you with our products and services.
• Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements.
• Fulfil the purposes for which you provided your personal information or that were described to you at collection, and as the CCPA otherwise permits.
• Improve our products or services, marketing, or customer relationships and experiences.
• Communicate with you about orders, consignments, and payouts.
• Notify you about changes to our products or services.
• Administer our systems and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Protect our Company, employees, or operations.
• Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
• Make suggestions and recommendations to you and other consumers about our goods or services that may interest you or them.
• Manage your consumer relationship with us, including for online account creation, maintenance, and security; and reaching you, when needed, about your account.
• Perform data analytics and benchmarking.
• Administer and maintain the Company’s systems and operations, including for safety purposes.
• Engage in corporate transactions requiring review of consumer records, such as for evaluating potential Company mergers and acquisitions.
• Comply with all applicable laws and regulations.
• Exercise or defend the legal rights of the Company and its employees, and customers.
• Respond to law enforcement requests and as required by applicable law or court order.

Sensitive Personal Information Use and Disclosure Purposes

We may use or disclose sensitive personal information for the following statutorily approved reasons (“Permitted SPI Purposes”):

• Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect.
• Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
• Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at the Company.
• Ensuring physical safety.
• Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not disclose the sensitive personal information to another third party, or use it to build a profile about you or otherwise alter your experience outside your current interaction with the Company.
• Services performed for the Company, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.
• Activities required to verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or to improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.
• Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.

We do not use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes.

Additional Categories or Other Purposes

We 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. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.

We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not attempt to reidentify the information, except to determine whether our deidentification processes satisfy any applicable legal requirements.

Disclosing, Selling, or Sharing Personal Information

Business Purpose Disclosures

We may disclose the personal information we collect, including sensitive personal information, to service providers and contractors for the business purposes described in the Personal Information Collection, Use, and Disclosure Purposes section and in the table below, such as to support our business functions. For example, we may disclose your address to our shipping carrier to deliver your order.

We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA’s other contract requirements for engaging service providers or contractors.

The chart below identifies the categories of entities to whom we have disclosed our consumers’ personal information for a business purpose over the preceding 12 months, along with the personal information categories disclosed and the disclosure’s business purposes.

Category of Information	Purpose
Identifiers such as basic contact details and certain order and account information.	To deliver products you purchased from us. To support customers with using our products and services, including online account management and troubleshooting.
Personal information categories listed in the California Customer Records statute such as basic contact details and certain order and account information.	To deliver products you purchased from us. To support customers with using our products and services, including online account management and troubleshooting.
Commercial information such as order information, shopping information and customer support information.	To deliver products you purchased from us. To support customers with using our products and services, including online account management and troubleshooting. To deliver location-based advertising.
Internet or other similar network activity, such as Usage Data.	To support customers with using our products and services, including online account management and troubleshooting. To deliver location-based advertising.
Geolocation data such as locations determined by an IP address or other technical measures.	To deliver location-based advertising.

Selling or Sharing Personal Information

We do not sell your personal information to third parties.

Your Rights and Choices

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

Right to Know and Data Portability Requests

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know”), including the specific pieces of personal information we have collected about you (a “data portability request”). You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:

• The categories of personal information we collected about you, and the sources from which we collected it.
• The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
• If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we disclosed for a business purpose to each category of persons, and sold or shared to each category of third parties.
• When your right to know submission includes a data portability request, a copy of your personal information, subject to any permitted redactions.

For more on exercising this right, see Exercising the Rights to Know, Delete, Correct, or Access ADMT.

Right to Delete and Right to Correct

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 and limitations (the “right to delete”). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers to take appropriate action.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the “right to correct”). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.

For more on exercising these rights, see Exercising the Rights to Know, Delete, Correct, or Access ADMT.

Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes

You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA’s Permitted SPI Purposes (the “right to limit”). Once we receive your valid request, we will limit the use and disclosure of your sensitive personal information to the Permitted SPI Purposes. For more on exercising this right, see Exercising the Right to Limit, Opt-Out, or Appeal an ADMT Decision.

For more on the Permitted SPI Purposes, see Sensitive Personal Information Use and Disclosure Purposes.

Personal Information Sales or Sharing Opt-Out and Opt-In Rights

You have the right to request that businesses stop selling or sharing your personal information at any time (the “right to opt-out”), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer’s parent or guardian for consumers under age 13 (the “right to opt-in”).

We cannot sell or share your personal information after we receive your request to opt-out unless you later consent to the sale or sharing of your personal information. For more on exercising your opt-out rights, see Exercising the Right to Limit, Opt-Out, or Appeal an ADMT Decision.

ADMT Rights (Effective January 1, 2027)

When a business uses automated decision-making technology (ADMT) to make significant decisions about you, you may have rights to:

• Obtain certain information about how the business uses ADMT, that is specific to you (the “ADMT access right”).
• Opt-out of the ADMT use (the “ADMT opt-out right”) unless the business provides you with a method to appeal the decision to a human reviewer with the authority to overturn the decision (the “ADMT appeal right”) or another exception applies.

ADMTs are technologies that process personal information and use computation to execute a decision and either replace or substantially replace human decision-making, resulting in decisions made without human involvement. Decisions are significant when they result in the provision or denial of financial or lending services, housing, education enrollment or opportunities, employment or independent contracting opportunities or compensation, or healthcare services. Advertising is not a significant decision.

For more on exercising your ADMT access right, see Exercising the Rights to Know, Delete, Correct, or Access ADMT.

Right to Non-Discrimination

You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

How to Exercise Your Rights

Exercising the Rights to Know, Delete, Correct, or Access ADMT

To exercise the right to know (including data portability), delete, correct, or access ADMT described above, please submit a verifiable request to us by either:

• Emailing us at privacy@inkvaan.com; or
• Writing to us at 6125 Luther Lane, PO Box #217, Dallas, Texas 75225, US.

Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know, including for data portability, twice in a 12-month period.

Exercising the Right to Limit, Opt-Out, or Appeal an ADMT Decision

You can submit your request to limit, opt-out, or appeal an ADMT decision by either:

• Emailing us at privacy@inkvaan.com; or
• Writing to us at 6125 Luther Lane, PO Box #217, Dallas, Texas 75225, US.

You can also submit your request to opt-out of personal information sales and sharing through an opt-out preference signal.

Verification Process and Authorized Agents

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, correct, or access ADMT related to your personal information. We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your personal information.

We cannot respond to your request to know, delete, correct, or access ADMT if we cannot verify your identity or authority to make the request and confirm the personal information relating to you.

For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer’s name, email address, or account username.

Responding to Your Requests to Know, Delete, Correct, or Access/Appeal ADMT

We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please contact us at privacy@inkvaan.com.

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.

Any disclosures we provide will cover information for the 12-month period preceding the request’s receipt date. We will consider requests to provide longer disclosure periods that do not extend past January 1, 2022, unless providing the longer timeframe would be impossible or involves disproportionate effort.

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 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.

Response and Timing on Rights to Limit or Opt-Out

In response to your request to limit or opt-out, we will process your request, as soon as feasibly possible, but no later than 15 business days from the date we receive the request. We will only use personal information provided from your request to comply with the request.

We will also notify our service providers, contractors, and certain other downstream recipients of your request to limit or opt-out and instruct them to both comply with your request, and forward the request to their own downstream recipients, if applicable.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us through these communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

Privacy Policy Changes

We reserve the right to update this CCPA Policy at any time. If we make any material changes to this CCPA Policy, we will update the policy’s effective date and post the updated policy on our website, https://inkvaan.com. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this policy, the ways in which we collect and use your information described here or your choices and rights regarding such use, please do not hesitate to contact us at:

Website: https://inkvaan.com/
Email: privacy@inkvaan.com
Postal Address: Inkvaan LLC, 6125 Luther Lane, PO Box #217, Dallas, Texas 75225, US

If you need to access this Privacy Policy in an alternative format due to a disability, please contact privacy@inkvaan.com.