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PRIVACY POLICY

EXTREMA RATIO

This Privacy Policy has been prepared to inform you about the collecting and processing of the Data you may provide us by using the website www.extremaratiousa.com (hereinafter, our “Website”).

1. OWNER AND DATA CONTROLLER.

Extrema Ratio U.S.A.
109 East 17th Street Suite 490
Cheyenne, WY, 82001

Owner contact email: [-]

2. PRIVACY STATEMENT

This Privacy Policy describes our information and privacy practices that apply when you use our Website and informs you how Extrema Ratio U.S.A. (hereinafter “We”) process your personal data. We believe that you should know what personal data We collect, and how you can affect the collection and use of your personal data. In this Privacy Policy, We explain the purposes of collecting and use of your personal data as well as how We have ensured that you have adequate control over your own personal data. PLEASE READ THIS PRIVACY POLICY BEFORE YOU USE THE WEBSITE. Your use of the Website signifies that you have read and agree with all of the terms of this Privacy Policy and consent to the collection and use of your personal information by Extrema Ratio, as described in this Privacy Policy and any other notices you receive from us. If you do not agree with any part of this Privacy Policy, do not use the Website.

3. TYPES OF DATA COLLECTED.

Any type of use or authentication by you on our Website implies your acceptance of the processing and collecting, by us or through third parties, of, among others, the following Data:

(i) Personal Data: in the course of interacting with our Website, you may provide us with certain personal information about yourself from which you may be identified, including certain types of Automatically Collected Information (set out in Section 3(ii) below) which may be provided by you to us in several ways, including but not limited to, when you: (i) purchase product through the Website, (ii) contact us through the Website, (iii) create or access an account on the Website, or (iv) sign up to receive our email or SMS updates. Personal Data includes your full name, home or business address and/or other shipping address(es), billing address, phone number, email address, fax number, and other information that could be used to contact you via mail, in person, or online and/or to identify you personally, demographic information (such as your zip code, age range, and gender), password if you create an account, personal information you input into any search box, message box, or comment box, or any other open text box, such as if you fill out form to contact us, or otherwise fill out any form or participate in any portion of the Website that permits you to input information, and information regarding your knife purchases, including date of purchase, your purpose for purchasing the knife, and similar information.

(ii) Automatically Collected Information: when you access and use the Website, We automatically collect and store certain technical information about your visit, such as: (i) date and time of visit and duration of visit, (ii) site traffic patterns, pages viewed, and clickstreams including but not limited to abandoned cart data, (iii) type of web browser used, operating system/platform used, (iv) your IP address or mobile device ID, (v) your computer or device hardware model, operating system version, advertising identifier and unique application identifiers (which may uniquely identify your browser or device and assist us with targeted advertising), web browser type and language, wireless network, and mobile network information, (vi) the website(s) from which you linked to the Website and the website(s) you visit after you visit our Website, (vii) the location from which you access the Website.

(iii) Payment and purchase details: it includes Personal Data that you may provide us in connection with the purchase of products or services from us on our Website (for example, payment information such as credit card information and billing address, purchasing activities, product preferences etc.)

Unless specified otherwise, all Data requested by our Website is mandatory and failure to provide this Data may limit your access and/or availability of certain features or functions of our Website. In cases where our Website specifically states that some Data is not mandatory, you are free not to communicate this Data without consequences to the availability or the functioning of our Website.

If you are uncertain about which Personal Data is mandatory you are welcome to contact us.

Any use of Cookies – or of other tracking tools – by our Website or by the owners of third-party services used by our Website serves the purpose of providing you the products and/or the services you require, in addition to any other purposes described in this document, if available.

You are the sole and exclusive responsible for any third-party Personal Data obtained, published or shared through the Website and confirm that you have the third party’s consent to provide the Data to us.

4. MANNER OF DATA PROCESSING.

(i) Methods of Processing.

We take reasonable physical, electronic and organizational security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated hereunder. In some cases, the Data may be accessible to our employees and collaborators (administration, sales, marketing, legal, IT system), or external contractors (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies). Subject to applicable law, the Data collected may be shared and transferred to affiliated entities located outside the United States, including without limitation our parent company Extrema Ratio S.r.l. By using our Website or otherwise providing personal information to us, you agree to the international transfer and processing of your Data in accordance with this Privacy Policy.

(ii) Legal Basis of Processing.

As applicable, We may process your Personal Data based on the following legal basis:

• you have given your consent for one or more specific purposes. Note: Under some legislations, We may be allowed to process Personal Data until you object to such processing (“opt-out”), without having to rely on consent or any other of the following legal basis;
• the provision of Data is required for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
• the processing is required for compliance with a legal obligation to which We are subject;
• the processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; or
• the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Unfortunately, no data storage system, or system of transmitting data over the Internet or wireless network, can be guaranteed to be 100% secure, and no security system can prevent all security breaches. As a result, We do not and cannot guarantee the security of our servers, the means by which Personal Data is transmitted between your computer or device and our servers, or any Personal Data provided to us or to any third party to or in connection with the Website or otherwise. The safety and security of your Personal Data also depends on you. For example, you should not send us sensitive Personal Data via email, as this is not secure, and information sent via email is not encrypted.

(iii) Place.

The Data is processed at our operating offices or in any other places where the parties involved in the processing are located, including at the offices of our Italian parent company Extrema Ratio S.r.l.

(iv) Retention Time.

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

• Personal Data collected for purposes related to the performance of a contract between us and you shall be retained until such contract has been fully performed;
• Personal Data collected for the purposes of our legitimate interests shall be retained as long as needed to fulfill such purposes;
• We may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, We may be obligated to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

To determine the appropriate length of time for holding your Personal Data, We consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm, from unauthorized use or disclosure of your Personal Data, the purpose for which We process your Data and whether We can achieve those purposes through other means, along with the applicable legal requirements. You may also be able to ask us to remove your information from our databases, unless applicable laws require otherwise.

Note that even after you ask us to remove your information from our databases, it may be impossible to remove some information, such as information tracked in our web server log files and information that may reside in backup files. We may also retain Automatically Collected Information even after you request that We remove your information from our databases, for use in the aggregate and to analyze and improve the Website, our products, and our services. Your Automatically Collected Information may be retained for the purpose of serving targeted online advertising to you until you opt-out of receiving these advertisements, as described herein.

Further, even after you request that We remove your information from our databases, We may retain Personal Data and Automatically Collected Information for a limited time to comply with any applicable law, rule, regulation, or guideline, to prevent fraudulent activity, to protect ourselves against liability, and to allow us to enforce our contractual or other rights and to pursue available remedies and limit any damages We might sustain.

5. DATA PROCESSING PURPOSES.

The primary purpose for which We collect information about you is to fulfil the services you request from us. We also collect Personal Data (including Automatically Collected Information) for the following purposes:

(i) to perform our contract with you. To perform the services you request from us, e.g. to respond to your information requests, to create an account for you, to fulfil your product orders and process payments, or to otherwise respond to your actions on the Website;

(ii) for our legitimate interests such as:

• to make important service communications regarding product recalls or safety issues and/or provide required legal notices;
• for certain marketing communications;
• to help diagnose problems with the Website;
• to analyze statistical use patterns and demographic data;
• to improve our Website, products and Extrema Ratio’s services;
• to generally run the Website and for internal operations, in order to provide you with an up to date, efficient and reliable service; and
• for market research and analytical purposes, e.g. to understand what our Website users are looking at most frequently so We can recognize and deliver more of the desired features, products, and services and make our future services and marketing efforts more efficient and personalized for you.

The information that you give us and information about your order may be combined with other Personal Data (such as demographic information and past purchase history) available from our records and other sources. This information may also be shared with other third-party marketing partners to bring you offers of interest. These third parties may share your information with others and may use this information for their own interest-based advertising and commercial purposes.

(iii) to comply with our legal obligations:

• to comply with our legal and regulatory obligations (including under applicable data protection laws);
• for preventing, investigating and detecting crime, fraud or anti-social behavior and prosecuting offenders, including working with law enforcement agencies; and
• to fulfil our duties to our members, colleagues and other stakeholders;

Where We rely on consent to process your Personal Data, you have the right to withdraw your consent to these activities at any time, which will mean (unless another lawful basis applies to your data) that We will cease to process the affected data after consent is withdrawn. However, please note this may result in us being unable to provide you with certain features of the Extrema Ratio’s services.

6. Use of Personal Data for Marketing Purposes

We will contact you to provide information about products or services that may be of interest to you, or to provide other information regarding Extrema Ratio, upcoming events and promotions, new products, and other general information about our products and/or services.

With each marketing communication, you will be given the opportunity to opt-out of receiving future marketing notices by using the unsubscribe mechanism provided through the marketing communication. If you request that We not contact you for marketing purposes, We reserve the right to retain your contact information and to contact you for non-marketing purposes relating to your use of the Website and product purchases. We further retain the right to use your contact information to comply with our legal obligations, resolve disputes, and enforce our agreements.

You have the right to ask in writing not to receive direct marketing material from us. You can email us at info@extremaratiousa.com with a request to be “opted out” from our direct mail communications. Once properly notified by you, We will take steps to cease direct mail communications to you.

7. THE RIGHTS OF USERS.

(i) Users’ Rights.

You may exercise certain rights regarding your Data processed by us. In particular, you have the right to do the following:

• withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data;
• object to processing of your Data. You have the right to object to the processing of your Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below;
• access your Data. You have the right to learn if Data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing;
• verify and seek rectification. You have the right to verify the accuracy of your Data and ask for it to be updated or corrected;
• restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of your Data. In this case, We will not process your Data for any purpose other than storing it;
• have your Personal Data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your Data from us.

If you want to close your account, please contact us at info@extremaratiousa.com.

If you request that your Personal Data be changed or deleted from our databases and/or that We close your account, We will use commercially-reasonable efforts to remove your Personal Data from our databases.

(ii) Details about the Right to Object to Processing.

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.

(iii) How to Exercise these Rights.

Any requests to exercise your rights can be directed to us through the contact details provided in this Privacy Policy. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.

8. COOKIE POLICY.

Our Website uses Trackers, such as cookies and web beacons, to collect information about you when you use our Website and services. Cookies are small data files stored on your hard drive or in-device memory that help us improve our services and your experience, see which areas and features of our services are popular, and count visits. Web beacons are clear electronic images imbedded in a web page, website feature, or email, which can recognize certain types of information on your computer or device, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon. For example, We may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to the Website. We use web beacons to operate and improve the Website and email communications and to statistically monitor how many people are using the Website and opening our emails and for what purposes.

We also use cookies to:

• remember your preferences and allow you to enter your user name less frequently;
• uniquely identify each user session when you access our services;
• compile aggregated statistics to analyze how the services are used;
• present and communicate to you information that is targeted to your interests, including our content presented on another website and across devices; and
• measure the effectiveness of our Website, services, content, communications and advertising, including by placing web beacons to understand which emails and links have been opened by recipients.

(i) Cookies Preferences

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our services.

(ii) Interest-based Advertising

Some companies may use information collected on our Website to deliver advertisements on our behalf or other companies, targeted to your interests and preferences, on our Website or on other websites or applications you may visit, on your various devices, or on your social media feed, and to gauge their effectiveness.

How We Use Google Analytics

For analytics, We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics may set cookies on your browser or mobile device or read cookies that are already there to collect information. We do not combine the information collected through the use of Google Analytics with Personal Data. For more information on how Google collects, uses, and shares your information please visit http://www.google.com/policies/privacy/partners/.

You can control the information provided to Google and opt out of certain ads provided by Google by using one of the methods set forth in http://www.google.com/policies/privacy/partners/ or use the Google Analytics opt out browser add-on at http://tools.google.com/dlpage/gaoptout?hl=en

Strictly Necessary Cookies

These cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Website will not then work. These cookies do not store any Personal Data.

Performance Cookies

These cookies allow us to count visits and traffic sources so We can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the Website. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies We will not know when you have visited our Website, and will not be able to monitor its performance.

Functional Cookies

These cookies enable the Website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services We have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Targeting Cookies

These cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

9. ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING.

(i) Legal Action.

Your Personal Data may be used for legal purposes by us in Court or in the stages leading to possible legal action arising from improper use of our Website.

You acknwoledge and agree to be aware that We may be required to reveal Personal Data upon request of public authorities.

(ii) Additional Information about Users’ Personal Data.

In addition to the information contained in this Privacy Policy, the Website may provide you with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

(iii) System Logs and Maintenance.

For operation and maintenance purposes, We may collect files that record interaction with our Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

(iv) Information not Contained in this Policy.

More details concerning the collection or processing of Personal Data may be requested from us at any time. Please see the contact information at the beginning of this document.

(v) Changes to this Privacy Policy.

We reserve the right to make changes to this Privacy Policy at any time by notifying you on this page and possibly within the Website and/or – as far as technically and legally feasible – sending a notice to you via any contact information available to us. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of your consent, We shall collect new consent from you, where required.

***

10. ADDITIONAL INFORMATION FOR CALIFORNIA CONSUMERS.

Certain states, including California, require additional information regarding our privacy practices and your privacy rights. Depending on whether you are a resident of those states, We provide you additional notices about our privacy practices and consumer privacy rights relating to your personal information or personal data, as defined under those laws.

This section of this Privacy Policy is dedicated to the rights of consumers residents in the state of California in accordance with the “California’s Shine the Light Act” and the “California Consumer Privacy Act of 2018” (the “CCPA“) as amended by the California Privacy Rights Act (“CPRA”) and other applicable laws and regulations. If you are a California resident, this section applies to you. Any provision of this Privacy Policy in conflict with CCPA does not apply with respect to consumers residing in California. The terms uwsed herein, including, but not limited to, personal information, are used with the same meaning as they do in CCPA.

(i) California Residents’ Rights under the Shine the Light Law.

You have the right, subject to certain limits under California Civil Code section 1798.83 and other applicable laws and regulations, the right to request in writing from businesses with whom they have an established business relationship, (i) a list of the categories of personal information, such as name, address, e- mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties.

To request the above information, please e-mail us at info@extremaratiousa.com and reference California Disclosure Information. We will respond to such written requests within info@extremaratiousa.com days following receipt of the e-mail as stated above.

(ii) California Residents’ Rights under the CCPA.

If you are a California resident, you have the following rights:

• the right to request information about your personal information that We have collected, used, sold or disclosed to third parties within the past 12 months;

In particular, you have the right to know: (i) the categories of personal information We may have collected, used, sold or disclosed in the last 12 months; (ii) the sources of that personal information by category; (iii) the business or commercial purposes of us for collecting, sharing or selling your personal information in the last 12 months; (iv) the categories of third parties to whom We shared or sold your personal information in the last 12 months; (v) the categories of personal information We shared or sold to third parties; and (vi) how We collect your personal information.

• The right to access to specific information;

This right includes, also, access to information about the specific pieces of personal information collected about you.

• The right to portability;

You have the right to obtain from us all the information you request in a format that facilitates its reuse in another context and to enable you to transmit the information to another entity without any obstacles.

• The right to request deletion;

With certain exceptions defined in the CCPA and other applicable laws and regulations, you have the right to request that We delete any personal information that We have collected from you. Once We verify your request, if no legal exception applies, We will delete your personal information and ask our service providers to do the same.

• The right to Opt-Out of Sale of personal information;

Californian consumers have the right to request that a company not sell their personal information for money. We do not sell your personal information for money. If you have any questions about how We process your personal information please contact us at info@extremaratiousa.com

• The right to be notified of financial incentives;

You have the right to be notified and informed of any financial incentives and their material terms, as permitted by CCPA, that We may offer. You have the right to waive those incentives, at any time, and, without your prior written consent, which you can revoke, you are not included and you not participate in these financial programs.

• The right to Non-Discrimination

You have the right to get a equitable service and not be discriminated if you exercise any of your CCPA rights, unless otherwise permitted by CCPA. For example, We will not deny you products or services, charge different prices, provide a different quality of services.

(iii) Categories of Personal Information.

• Identifiers: including, but not limited to, name, surname, username, email address, unique personal identifier, online identifier, postal address, driver’s license number, passport number;
• Personal information under California or federal law: including, but not limited to, physical characteristics, telephone number, signature, credit card number, or any other financial information, health insurance information;
• Geolocation data: including, but not limited to, country location;
• Professional or employment related information: including, but not limited to, job title;
• Commercial information: including, but not limited to, records of personal property, products purchased and preferences product;
• Internet or other electronic network activity information: including, but not limited to, search history and browser information;
• Inferences drawn from any of the information identified in this subdivision: including, but not limited to, information collected from the creation of a consumer profile.

(iv) How to Exercise your Rights.

To exercise your rights, you can submit a verifiable request to us by emailing us at info@extremaratiousa.com or by sending a letter to us at Extrema Ratio USA – 18 Bridge Street Unit 2A Brooklyn NY 112. Your request should be adequately detailed, in order to allow us to give you a proper answer. Once We received your request, We will verify your identity in order to be sure that you are the lawful person to submit such request. We will not respond to any request unless We are able to verify your identity and, therefore, confirm that the information We have collected relating to you. You can submit a maximum of two verifiable request within one year.

In order to submit a verifiable request, you can authorize in writing an authorized agent to make such request on behalf of you. The authorized agent must provide us (i) a power of attorney or (ii) other valuable proof that you have designed her/him as an authorized agent to submit the request on behalf of you. Please note that you have to provide us sufficient information to demonstrate your identity in order to verify that the information We have collected relating to you.

(v) Intended Users of the Website.

By accessing, providing information through, or otherwise using the Website, you affirm (i) that you are at least the age of majority; and (ii) that you have authority to agree to this Privacy Policy and are competent and capable of understanding and complying with this Privacy Policy. If We become aware that an individual is under the age of majority and has submitted any information to us, We will immediately delete his or her information from our files. If you are a parent or a guardian, and you are concerned that We have information of a child under the age of majority, please contact us by emailing us at info@extremaratiousa.com.

11. DEFINITIONS AND LEGAL REFERENCES.

For purposes of this Privacy Policy, the following terms shall have the meanings set forth below:

“Personal Data” (or “Data”).

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

“Usage Data”

Information collected automatically through our Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the users who use our Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by you, the various time details per visit (e.g., the time spent on each page) and the details about the path followed within our Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the user’s IT environment.

“Data Controller”

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of our Website. The Data Controller, unless otherwise specified, is the owner of this Website.

“Cookie”

Cookies are Trackers consisting of small sets of data stored in the user’s browser.

“Tracker”

Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of users, for example by accessing or storing information on the user’s device.

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