PRIVACY POLICY
Last Updated: April 2023

INTRODUCTION
Lugano Prive LLC (“Lugano,” “us,” “we,” or “our”) respects the privacy concerns of our customers and all users of products and services. We are committed to protecting and respecting your privacy. This Privacy Policy (the “Privacy Policy”) and any other documents referred to in it sets forth the basis on which any personal information we collect from you, or that you provide to us, in connection with our Services will be processed by us. We are providing this Privacy Policy so that you can better understand how we collect, use, and share information that is gathered using our Services.

Our privacy practices are subject to the applicable laws of the places in which we do business, so we have added region-specific terms that only apply to customers located in certain geographic regions, or as required by applicable laws.

This Privacy Policy includes the following sections:

1. Scope of this Notice
2. Personal Data We Collect and How We Use It
2.1 Personal Information You Give Use
2.2 Personal Information We Derive Through Your Use of Our Services
2.3 Personal Information We Collect From Third Parties
3. What We Do With Your Personal Information
4. Our Legal Grounds for Processing Your Personal Information
5. Our Sharing of Your Personal Information
6. Publicly Posted Content
7. Data Retention
8. Data Security
9. International Data Transfers
10. Your Privacy Rights and Choices
11. Children’s Data
12. Jurisdiction-Specific Privacy Disclosures
13. Changes to this Notice
14. Contact us

1. SCOPE OF THIS NOTICE

This Privacy Policy describes Lugano’ practices for collecting, using, maintaining, protecting, and disclosing (“processing”) your personal information when you use our services (“Services”), such as when you:

· Visit our website at luganoprive.com (the “Site”) and any other sites or application that link to this Privacy Policy.
· Open a membership account with Lugano.
· Attend a social or business event sponsored by Lugano.
· Make a purchase or other transaction with us.
· Subscribe to or engage with our newsletters or other electronic communications.
· Interact with our social media pages.
· Click on our ads posted on third party sites.
· Communicate with our service representatives or features (including via chat functions, email, text, or phone).
· Use our Services anywhere we collect information from you and refer to this Privacy Policy.

This Privacy Policy also applies to personal information we collect from third parties about you.

This Privacy Policy does not apply to:

· Third-Party Sites. Websites, apps, videos (embedded or direct links), or other content (each a “Linked Site”) to which we link that are not operated by us. Linked Sites have their own personal information collection and use practices, and we are not responsible those practices. We encourage you to read each Linked Site’s privacy disclosures to understand how your personal information is processed.

· Job Applicants and Workforce Members. Our processing of the personal information of job applicants/candidates and workforce members is not governed by this policy. California residents may view or Workforce Member Privacy Policy for more information about the personal information we process about job applicants and workforce members.

· Non-Personal Information. Our processing of information that cannot be linked to an identifiable or identified individual. We may process this data for any legitimate business purpose.

2. PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

The personal information we collect about you depends on the nature and context of your interaction with Lugano and our Services. It may also depend on various choices you make about how to use the Services we offer, the functionality and features you choose or enable, your location, the devices you us to interact with our services, and applicable law. The following describes the personal information we collect about you and the way we collect it.

2.1 PERSONAL INFORMATION YOU GIVE TO US

We collect the following categories personal information you provide to us, including the following:

· Your Personal Details. For example, your first and last name, email address, phone number, physical address, job titles, and other contact information you provide.
· Account and Other Identifiers. For example, a username, account ID, customer number, or similar identifier that can be used to identify a user or account.
· Government Identification. We collect government identification as part of our legal obligations and security protocols.
· Image and Likeness. While attending events sponsored by Lugano, you may be photographed or recorded via video and/or audio.
· User Preferences and Interests. We collect information about your preferences, including your preferred jewelry styles, personal interests, philanthropical endeavors, food and beverage preferences, allergies, and dietary restrictions.
· Messages and email data. We collect information about you when you send, receive, open, read or otherwise engage with messages, email, or other communications in connection with our Services, including whether you have opened or acted on those communications.
· Social Media Content. We view interactions with our social media pages and content you post on them.
· Other Personal Information You Provide. If you provide us personal information other than that described above, we will collect it and use it for the purposes for which you provide it or other consistent purposes.
· Inferences. In certain instances, we may infer personal information about you based on the information you have provided to us or that we have collected about you. This may include your overall financial status, your social interests, and affinities.
· Payment processing information. We collect information related to payment processing for purposes of completing transactions. We do not store credit card information directly and process payment through secure service providers.
· Demographic information. We collect information that reveals your racial or ethnic origin, religious or philosophical beliefs, union membership, political opinions, or sex life or sexual orientation, associated family members,

2.2 PERSONAL INFORMATION WE DERIVE THROUGH YOUR USE OF OUR SERVICES

We use cookies and similar technologies to collect information about the use of our website in order to make it function effectively and also to improve our website visitors’ experience when they browse our website. The information we collect using these technologies includes:

· Device and Browser Identifiers. For example, an assigned user ID, IP address, or similar identifier that can be used to identify your device.
· Coarse Location Information. A general approximation of your location that is not based on global position system (GPS) information.
· Browsing and Search History. Information about the content you view and searches you make on our Site(s).
· Website Log and Usage Data. Information related to our pages you viewed, the services and features you used or interacted with, your browser type and details about any links or communications with which you interacted.

Certain browsers may provide individuals with the ability to communicate that they wish not to be tracked while browsing on the Internet. We currently do not have the ability to respond to such “Do Not Track” signals.

2.3 PERSONAL INFORMATION WE COLLECT FROM OTHERS

We mostly collect personal information directly from you or based on your interaction with our Site. However, we also may collect personal information from third-party sources. These include our Business Services Providers, Marketing and Advertising Providers, government entities, our Lugano affiliates, social media platforms, and other users of our Services. Even if you are not a registered user of our Services, your information might still be collected.

3. WHAT WE DO WITH YOUR PERSONAL INFORMATION

We may use your personal information for a variety of reasons. Depending on how you interact with our Services, these include using personal information for the following purposes:

· Delivering Our Services to you and to provide the related customer support, communication, and security.

· Processing Transactions to process or fulfill orders and transactions, verify customer information, process payments, confirm eligibility promotional benefits, and perform similar activities.

· Customer Service and Development to provide customer service, maintain and service products and accounts, provide training for quality assurance purposes, develop customer audiences, and perform similar activities.

· Advertising & Marketing to send advertisements and marketing material via physical and electronic mail relating to product specials and other promotional events or offers, perform marketing research and data analytics, and perform similar activities.

· Online Advertising to serve ads to you on other websites.

· Counting Ad Impressions & Website Interactions to audit interactions with our websites, applications, or advertisements, count ad impressions to unique visitors, verify position and quality of ad impressions, and perform similar activities.

· Fraud Prevention to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for that activity.

· Public Health and Safety to conduct screening or temperature checks for COVID-19 symptoms or similar screening activities related to public health and safety.

· Defending Against Claims & Litigation to defend against or respond to potential or actual claims and litigation.

· Policy Enforcement, including enforcing our terms of service, legal compliance policies, and other similar policies.

4. OUR LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL INFORMATION

When we process personal information about you to comply with legal requirements or to perform our obligations under a contract with you or with our customer through whom you use our offerings, failure to provide such information may prevent or delay our fulfillment of these obligations.

To the extent required by applicable law, we will collect your personal data with your consent, where required, and in accordance with our legitimate need to provide our Services.

Lugano may be required by some jurisdictions to rely on one or more legal bases to collect, use, share, and otherwise process the information we have about you. We describe these legal bases and some accompanying examples in more detail below.

· Performing our Agreement. Lugano processes your information as is necessary to perform our contract with you, the Terms of Service. For example:

o If you are located outside of the United States, we transfer your information to the United States to provide our Services.

· Your Consent. Lugano processes certain information based on your consent, which you may revoke at any time. For example:

o We and our partners use cookies and similar technologies, as described in more detail in our Cookie Policy, based on your consent.

o Where you choose a method of verification to confirm your address, we do so in accordance with your consent.

o If you decide to use location services in the context of Lugano, we collect and process such location information based on your consent.

o We rely on your consent to tailor ads based on your activity and information on other websites and partner data, such as inferred interests.

o We will send you marketing communications where you have consented to receiving such communications in accordance with applicable law.

· Legal Obligation. Lugano may process your information to comply with a legal obligation, a court order, or to exercise and defend legal claims. For example:

o We may preserve and disclose your information if it is necessary to respond, based on applicable law, to a valid legal request (e.g., a subpoena, search warrant, court order, or other binding request from government or law enforcement).

o We may retain and process your information where it is necessary for compliance with applicable tax laws.

· Vital Interests. Lugano may process your information in certain circumstances when it is necessary to protect your vital interests, or those of others. For example:

o We may need to process your information in order to protect your life or safety or the lives or safety of others, or otherwise prevent physical injury or other harm to any person or the general public.

o We may preserve or share your information with law enforcement and related authorities where we have a good faith belief that it is required in the context of an imminent threat.

o We may share your personal data with disaster relief agencies, first responders and other individuals to facilitate disaster or emergency response efforts.

· Legitimate Interests. We may process your information where it is necessary for the purposes of Lugano or a third party’s legitimate interests. We process your information in furtherance of the following legitimate interests:

o Providing, improving, and developing our Services. We use your information to provide our Services, including any personalized services, and to understand and improve our business and our user relationships.

o Sending marketing communications. We rely on our legitimate interests in marketing and promoting our Services to use your contact information and send you marketing communications in accordance with applicable law, except where applicable law requires that we rely on your consent to send such communications.

o Sharing information for legal and safety reasons. Where required for legal and safety reasons, we may disclose information to law enforcement and related agencies and authorities in furtherance of the legitimate interests described further below.

5. OUR SHARING OF YOUR PERSONAL INFORMATION

We may share your personal information with the following:

Business Services Providers. These are those persons or entities with whom we have a relationship to provide business operations services and support to Company. These providers may include the following:

· IT Operations Providers. These include cloud computing service providers, internet service providers, data backup and security providers, functionality and infrastructure providers, and similar service providers.

· Operations Providers. These include service provider with whom we partner to provide day-to-day business operations, including payment processors, security vendors, business software service providers, hospitality service providers, banks, facilities management providers.

· Professional Advisors. These include lawyers, accountants, consultants, security professionals, and other similar parties when disclosure is reasonably necessary to comply with our legal and contractual obligations, prevent or respond to fraud or abuse, defend ourselves against attacks, or protect the rights, property, and safety of us, our customers, and the public.

Marketing and Advertising Providers. These include advertising, direct marketing, and lead generation providers, affiliate marketing program providers, retargeting platforms, data brokers, ad networks, marketing consultants, and similar services providers.

Affiliates. Our affiliates and any subsidiaries, joint venturers, or other companies that we control or that are under common control with us.

Legally Required Parties/Governmental Entities. Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.

Reorganization. Persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.
Authorized Disclosures: To any party when authorized by the individual to whom it pertains to share it.

6. DATA RETENTION

We will retain your personal information only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements. In some circumstances, you may ask us to delete your information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. DATA SECURITY

We have implemented and maintain reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply common protections described in this policy. These protections align with well-known standards such as ISO 27001:2017 and others.

8. INTERNATIONAL DATA TRANSFERS

We are located and operate in the United States. By submitting personal information to us, you understand that we may transfer your personal information to country foreign to you, including the United States, for processing. The laws that apply to the use and protection of personal information in the United States, or other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. These transfers may include transfers to our service providers located in foreign jurisdictions. Whenever we engage a service provider, we require that its privacy and security standards adhere our requirements and applicable privacy laws.

9. YOUR PRIVACY PREFERENCES

You can control the collection and use of personal information for some of our processing activities. This includes:

· Adjusting Communication Preferences

Emails From Lugano: The Site presents you with the option to provide your email address and other personal information in order to opt in to receive email communications, including promotional emails. If you wish to no longer receive email communications, you can click on the “unsubscribe” link located at the bottom of the email, email Lugano at [email protected] to let us know, and we will remove you as soon as possible. Opting out of marketing or newsletter emails will not opt-you out of all emails—we may need to send you transactional or similar emails related to your Lugano purchases, legal or contractual updates, or similar topics. You are not able to opt-out of these emails.

Text Messages: You may opt out of automated text notifications any time by replying “STOP,” or any alternative keyword we have shared with you. You may still receive communications from Lugano regarding safety issues, such as messages related to your account, even if you have opted out.

· Blocking Cookies

Most web browsers automatically accept cookies by default, but you can alter how your browser responds to cookies by adjusting the settings. Information about managing cookies for popular web browsers can be found in the links below:

Safari (Desktop) and Safari Mobile (iOS).
Firefox
Chrome
Microsoft Edge
Brave

Many websites, including ours, employ Google Analytics. Google Analytics works using cookies. Google Analytics cookies collect your IP address; however, because IP anonymization is used on this website, your IP address will be shortened (and therefore anonymized) as soon as technically possible and before it is stored or otherwise used in connection with Google Analytics. The anonymization process takes place within the European Union or the European Economic Area, except in exceptional cases, where your full IP address may be sent to a Google server in the United States and shortened there. We use the information collected by Google Analytics cookies to find out about how visitors use our website. Google will not combine the IP address sent by your browser in connection with Google Analytics with other data. You can prevent Google Analytics cookies from being stored by setting your browser software accordingly. To opt out of Google Analytics data collection, follow these instructions from Google.

10. YOUR PRIVACY RIGHTS

Some jurisdictions provide covered individuals with specific privacy rights which can be exercised against covered entities. Depending on the jurisdiction, these rights may include the following:

· Access and Portability. The right to know (or confirm) what personal information a business has collected about you, and to receive a copy of it.

· Deletion/Restriction. The right to request that a business delete personal information it has collected from you or restrict how it is used, subject to certain exception.

· Correction/Rectification. The right to request correction of inaccurate personal information maintained by the business.

· Opt-Out of the Sale/Sharing of Your Personal Information. The right to opt-out of the sale of your personal information to third parties. The term “sale” varies by jurisdiction, but sometimes includes the right to opt-out of the use of personal information for targeted advertising purposes.

· Revoke Consent. Where consent is required for processing under applicable law, you may withdraw your consent to the processing of your information at any time.

· Object to Processing. Object, on grounds relating to your situation, to our processing of personal data concerning you which is (i) necessary for the performance of a task carried out in the public interest, (ii) carried out in the exercise of official authority vested in us, or (iii) processed by us on the basis of our legitimate interest. In this case, where applicable, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

· Limitation/Restriction. The right to limit or restrict a business’s use or disclosure of certain personal information.

· Opt-out of Profiling/Automated Decision-Making: The right to opt- out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

· Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred at law.

· Complaints. The right to lodge a complaint with the appropriate governmental authority.

Lugano will honor the privacy rights afforded to individuals in accordance with applicable law and will not discriminate against individuals for exercising their privacy choices under the law.

Exercising Your Privacy Rights

You may make a request at any time to exercise your access, deletion, correction, and restriction rights listed above by emailing us at [email protected]. We will respond to your request within a reasonable period (if properly submitted) and in accordance with applicable law. If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. If we decline to act regarding your request, we will inform you of our decision and the reason for it, and, if applicable, with instructions on how you may appeal our decision.

11. CHILDREN'S PRIVACY

Our Services are not intended for persons under 16 years of age. We do not knowingly collect or process the personal information of individuals under the age of 16. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us their Personal Information, please contact us at [email protected].

12. JURISDICTION-SPECIFIC PRIVACY DISCLOSURES

12.1 MEMBERS OF THE EUROPEAN ECONOMIC AREA AND THE UNITED KINGDOM

You may lodge a complaint with a supervisory authority at any time if you are of the opinion that the processing of personal data relating to you violates applicable law. If the complaint relates to provisions of the EU and UK GDPR, you can lodge such complaint with a supervisory authority in the Member State of your place of residence, your place of work or the place of the alleged infringement. You may identify the applicable supervisory authority based on your location on the European Data Protection Board website. If the complaint relates to provisions of the UK GDPR, you can lodge such complaint with the Information Commissioner’s Office. For contact details of your local Data Protection Authority, please see: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

12.2 CALIFORNIA

Please see our California Privacy Policy which supplements this Privacy Policy.

12.3 NEVADA

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

13. CHANGES TO THIS NOTICE

We may update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access our Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

14. CONTACT US

If you have questions or comments about this Privacy Policy or complaints and our privacy practices, please contact us at:

Email: [email protected]
Address: 545 Newport Center Dr., Newport Beach, CA 92660
Phone: (949) 514-6431