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theBespoke\\WellnessGroup – Revised and posted as of: January 1, 2023

TheBespoke\\WellnessGroup of Companies (“TheBespoke”,”Company”, “we”, “our”, or “us”) comprising of Dr. Elaine Chin Medicine Professional Corporation, Executive Health Centre, Innovation Health Group, Bespoke Wellness Club and Health-in-a-Box, understand that privacy is important to our users. This Privacy Statement describes our practices regarding the collection, use, sharing, and protection of your personal information in connection the services, products, features, and offerings we provide to you (the “Services”), including without limitation our print magazine subscriptions, and our digital Services like TheBespoke.com, TheBespoke mobile applications, TheBespoke newsletters, and TheBespoke’ other digital sites, communications, and media (the “Site”) (collectively, the “Properties”). This Privacy Statement also tells you about the rights and choices you have with respect to your personal information, how you can assert those rights, and how you can contact us to get answers to your questions.

With respect to the personal information that our clients and their vendors collect from you outside of our Properties (“Service Data”), where permitted by law, we generally process such information only as a “service provider” or “data processor” (as those terms are defined under applicable data protection laws) on behalf of our clients, who act as the “business” or “data controller” (as those terms are defined under applicable data protection laws). Our partnerss—for example, companies that use your personal information to process a medical diagnostic service or ship you products—are the parties that control the use of the Service Data and determine the purposes for which we process such information. While this Privacy Statement describes how we process Service Data on behalf of our partners, our partners are responsible for their own practices in collecting, using, and disclosing information they collect from you. To learn more about such partners’ use of your information and your rights that you may have over such information, please consult the privacy policy of the applicable company.

Please note that our privacy practices are subject to the applicable laws of the regions in which we operate. Accordingly, some additional region-specific terms will only apply to individuals in those locations, or as required by applicable laws.

BY USING OR ACCESSING THE PROPERTIES, YOU AGREE TO THIS PRIVACY STATEMENT. IF YOU DO NOT AGREE WITH OUR POLICIES OR PRACTICES, YOU SHOULD NOT USE OR ACCESS THE PROPERTIES OR PROVIDE US WITH ANY PERSONAL INFORMATION.

WHAT OUR PRIVACY STATEMENT COVERS

This Privacy Statement applies only to user information collected by us or shared with us in relation to our Properties. While you may encounter links on the Properties to other websites, such as those relating to our third-party sponsors, advertisers, and other partners (e.g., our affiliate network operators), please note that these websites are not covered by this Privacy Statement (unless otherwise noted on such site, which may be the case if, for example, the site is also owned and operated by TheBespoke).

We may provide different or additional privacy notices in connection with certain activities, programs, and offerings (for example, if you submit a job application through the Properties). Additionally, we may provide additional “just-in-time” notices or notices at collection that may supplement or clarify our privacy practices or provide you with additional choices regarding your personal information.

This Privacy Statement does not apply to the activities of TheBespoke’ third-party sponsors, advertisers, and other partners (e.g., our affiliate network operators) that may collect your personal information while you access or use such third party’s services in connection with your use of our Properties (e.g., social media and sharing services, widgets, and/or interactive mini-programs that run on the Properties). This Privacy Statement also does not apply to TheBespoke’ third-party licensees, who manage and run their own TheBespoke-branded services and sites, some of whom the Properties link out to. The privacy and information practices of those third parties are not covered by this Privacy Statement. To learn more about the policies of such third parties, we encourage you to read and review the privacy statements of each third-party service that you may choose to use.

We offer widgets that are hosted on the Properties, such as our embeddable video player. Use of the TheBespoke.com widgets is subject to our Site’s Terms of Use, but downloading or embedding these widgets on other websites is not covered by this Privacy Statement.

PERSONAL INFORMATION WE COLLECT FROM YOU

We use the term “personal information” – also called “personal data” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. The following are categories and types of personal information that we may collect from or about you, depending on how you interact with the Properties:

  • Identifiers, such as your name and email address;
  • Contact information, such as your mailing address and telephone number;
  • Payment information, such as credit or debit card information;
  • Transaction information, such as your subscriptions and purchases with us;
  • Profile information, such as photos, videos, or other information about you and your interests posted or included in connection with a user profile;
  • Job and employment information, such as the name of your company, industry, and job title;
  • Education information, such as school attended and degree obtained;
  • Preferences, such as marketing preferences and choice of subscription;
  • Devices and online identifiers and related information, including internet protocol (IP) address, mobile ad identifiers, data collected from cookies, beacons, and pixel tags, and similar unique identifiers;
  • Internet or other electronic network activity information, including, but not limited to browsing history, search history, and information regarding your interaction with an internet website, application, email, mobile app, or advertisement;
  • Geolocation or other information that permits us to determine your location;
  • Demographic information, such as your age or the gender you identify as;
  • Inferences we may create about you;
  • Any other personal information that you or somebody on your behalf voluntarily provide us.

If you interact with us on social media or use features such as plugins, widgets, or other tools made available by social media platforms or networks in connection with our Properties, or if you choose to sign up for a paid subscription via your social media profile, we may collect information that you share with us on social media or that such platforms share with us. Please review the privacy policies and settings of the social media platforms and networks that you use for more information about their privacy practices. For additional information, see the section titled Third-Party Sources below.

Where you sign-up for paid subscriptions as a gift option (e.g., on behalf of a friend or colleague, the gift recipient), you may provide us with personal information on behalf of the gift recipient.

HOW WE COLLECT YOUR PERSONAL INFORMATION

Personal Information You Provide

We collect personal information that you provide to us directly. This may include, but is not limited to, information you provide:

  • When you contact us via phone, email or text message, or through other Internet-enabled communications;
  • When you subscribe to one of our print or digital Services;
  • When you register to become a member of the Site or create a user profile;
  • When you register for one of our live or virtual events;
  • On your member profile page and public profile URL (for example, if you choose to add content to your profile page, such as photos, videos or other information about you and your interests);
  • To enter into a sweepstakes, contest, or promotion, or to apply for consideration in connection with a TheBespoke list or similar accolade (e.g., Under 30 list applications);
  • When you order something from the Properties or one of our co-branded websites;
  • When you post content to the Properties;
  • In your response to surveys that you choose to complete for us;
  • When you make search queries on the Properties; and
  • When you otherwise voluntarily provide us with personal information on or through the Properties.

You always have the option not to provide the information we request. If you choose not to provide the information we request, you can still access and use portions of the Properties, but you may be unable to access certain options and services, such as paid subscription content. If you wish to provide user information to us about a third party, such your friend or colleague, in connection with a referral, gift subscription, recommendation, nomination (e.g., Under 30 list nomination), or other purpose, please only do so if you have the permission of that third party. When you register or become a member of the Site or provide information to TheBespoke in any other manner, you agree to provide only true, accurate, current and complete information.

Personal Information We Collect Automatically

When you visit our Properties, open or click on emails we send you, or interact with our advertisements, we or third parties we work with may automatically collect certain information using technologies such as cookies and other tracking technologies described below.

Cookies and Similar Technology

“Cookies” are pieces of information that may be placed on your device by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, for example, the address of the websites you visited before and after you visited our Properties, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Properties you visited and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, pixels, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Properties. We may also use cookies to customize your visit to the Properties (including our emails) and for other purposes to make your visit more convenient or to enable us to enhance the Properties. 

Cookies fall into the subcategories below:

Required Cookies. Certain cookies are used for specific purposes that are essential to your secure use and navigation of the Properties. Without them, TheBespoke may not be able to provide core Property functions and features to you, and the Property would not operate as well as you or TheBespoke would like. These cookies collect and use information such as your server preferences, single-session data and corresponding identifier, web beacons and log files (detailed below), and other credential-related information.

Functional Cookies. Other cookies may be used to collect and process information about your preferences and similar choices in connection with the Properties in order to optimize your browsing experience (e.g., various local preference settings; which geographically-customized version of the Properties and related content you may prefer). Functional cookies include social media cookies, which collect information about your social media usage and other data you may have provided in connection with such usage (if you access the Site through a social media website or mobile application, you may have social media cookies). If you wish to modify or change your social media cookies, please visit and review the settings on your applicable social media account(s). Functional cookies also include analytics cookies, which provide us with data that allows TheBespoke to better understand its users and improve the Properties based on what we have learned from that data.

Advertising Cookies. To help support the Properties and further tailor your experience, TheBespoke and its advertising partners (and/or their third-party analytics providers) may also use cookies on the Properties (including in emails) to personalize the content and advertisements you may be shown. Such advertisements use cookies to provide you targeted advertisements that may be more consistent with your interests than non-targeted advertisements. Certain TheBespoke advertising partners may also use cookies to monitor or track the performance of their advertising content, including native advertising content (e.g., BrandVoice).

If you would like to manage your cookie preferences or learn more information about this practice and your right to decline (or opt-out of) cookies placed by some or all of these companies, please click here.

The Properties’ web and ad servers log information about a user’s IP address, browser type, and the current URL the user is requesting. This information is always provided by a user’s browser and automatically logged by most websites. These log files are stored in a secure location and used for internal business purposes such as internal analysis of traffic patterns within our Properties.

Clickstream Data

As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Properties. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Properties, how visitors navigate throughout the Properties, and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Properties.

Analytics

We may work with third-party vendors who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Properties. One such provider is Google Analytics, a web analytics service provided by Google LLC (“Google”). Google Analytics uses cookies to help analyze how users use the Properties. The information generated by these cookies about your use (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Properties, compiling reports on activity for its staff, and providing other services relating to web page activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. You may refuse the use of such cookies by selecting the appropriate settings in your browser. By using the Properties and accepting cookies, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Please refer to the currently available opt-outs for Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.

Service Data

We may obtain Service Data from or on behalf of our clients and their vendors, which we process on behalf of our clients in accordance with our contracts with them.

Third-Party Sources

From time to time, we may collect personal information about you from third party sources (including data append services such as public or social graph data, data co-ops for print magazine publishers, or social media websites if you have chosen to log in or connect your social media with our Properties) which we will use for our business or commercial purposes (for example, in order to contact you and/or to better serve you with content or promotions). However, we will only use this information where these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

When you sign into our Properties or purchase a paid subscription on our Properties using a social media log-in, you give permission to that social media company to share certain information with us. For example, if you sign in or purchase a subscription using Facebook or LinkedIn, you give permission to Facebook or LinkedIn (as applicable) to share with us your email address and certain other information in your social media profile that you have designated as public. This will be limited to your full name, age range, profile picture (if you have one) and link to your Facebook or LinkedIn profile (as applicable). If you log in or purchase a subscription using your Google account, you give Google permission to share personal information with us that you have made public in your Google profile. This will be limited to your full name, your email address (and whether your email has been validated), your age range, your profile picture (if you have one) and a link to your Google profile. If you log in or purchase a subscription using your Apple ID, you give Apple permission to share your personal information with us (however, you can choose to hide your email address and Apple will instead create a random email address so that your personal email can stay private). This email address will be linked to your account and allow you to access your subscribed content.

We will use the information described above to form a profile for your account, to enable you to purchase a paid subscription, and/or as otherwise set forth in this Privacy Statement. You have the option to later configure your Facebook, LinkedIn, or Google settings, or Apple ID to remove permissions for TheBespoke to access to this information. However, this will not affect our ability to use the information that we already received when you first set up your account (or purchased a subscription) using that social media login, so long as we use it for the purposes set forth in this Privacy Statement.

We may also obtain personal information of subscribers to TheBespoke licensees after such licensees stop conducting business under the TheBespoke license.

HOW WE USE YOUR PERSONAL INFORMATION

We collect and use personal information for the following purposes:

  • To communicate with you, which may include:
    • Contacting you about and providing you and our clients with our Services;
    • Responding to your direct inquiries, requests, issues or feedback, and providing customer service;
    • Adding you to our mailing or SMS lists and sending you emails or texts from time to time;
    • For users who have opted into receiving communications about TheBespoke’ third-party partners, sending you information about third-party partners that we think you may be interested in;
  • To provide our products and services, which may include:
    • Operating the Properties, and providing you with any specific services that you have requested;
    • Creating, maintaining, and otherwise managing your account, profile, or subscription;
    • Delivering content and product and service offerings relevant to your interests;
    • Fulfilling your orders and/or completing the transactions you have requested, processing your payments, and providing you receipts and order updates;
    • Providing a forum for discussion or community for TheBespoke honorees, asking questions, posting photos and reviews, and sharing experiences;
    • Considering you for and/or naming you to a TheBespoke list or other similar accolade (e.g., Under 30);
    • Organizing and managing live or virtual events;
    • Providing TheBespoke honorees with online profiles;
  • For marketing, advertising, and promotional purposes, which may include:
  • Marketing our goods and services or goods and services of those of our affiliates, business partners, and other third parties;
  • Providing you advertising for products and services that may be of interest to you;
  • Targeting relevant content and advertising to you on our Properties and elsewhere where we may be acting as a third party;
  • Administering sweepstakes, contests, and other similar promotions;
  • Conducting insights research for ourselves and our clients;
  • Tracking clicks on affiliated links;
  • Mailing you promotions or advertisements;
  • For analytics, enhancement, and personalization, which may include:
    • Identifying trends and making inferences about you and your interactions with us or our affiliates or our business partners;
    • Conducting research and analytics to improve our services and product offerings or those of our affiliates and business partners;
    • Understanding how you interact with our Services (including our Properties), advertisements, and communications with you to determine the appeal of our products or services, and to improve our Services and marketing campaigns;
    • Personalizing your experience to save you time when you visit our Properties, and to customize the marketing and advertising that we show you;
    • Better understanding our customers’ needs;
    • Providing personalized recommendations about our products and services;
    • Enhancing the information we may have with information from third parties;
  • For security and fraud prevention, which may include:
  • Helping maintain the safety, security, and integrity of our Properties, databases and other technology assets, and business;
  • Internal research; technological development and demonstration; and improving, upgrading, or enhancing our Properties;
  • Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity;
  • Investigating suspected fraud, harassment, or other violations of any law, rule, or regulation, or the policies for our Properties;
  • To comply with legal obligations, which may include:
  • Compliance with legal or regulatory obligations, establishing or exercising our rights, and to defending against a legal claim;
  • Responding to law enforcement requests and as required by applicable law, court order, legal process, or governmental regulation;
  • Acting in connection with a bankruptcy proceeding or the sale, merger, or change of control of the Company or the division responsible for the services with which your information is associated
  • To support core business functions, which may include:
  • Maintaining records related to business process management, sales, loss and fraud prevention, and to invoice and collect amounts owing to us;
  • Providing and maintaining the functionality of our Properties, including identifying and repairing errors or problems; and
  • For any additional purposes that you specifically consent to.

We may collect information that is not personal information (“non-personal information”), including information lawfully made available from federal, state, or local government records, or aggregate or de-identified information. Because non-personal information does not personally identify you, we may collect, use, and disclose such information for any purpose permitted by law. In some instances, we may combine non-personal information with personal information. If we combine any non-personal information with personal information, the combined information will be treated by us as personal information.

The Properties may offer features that allow you to post content. You should be aware that personal information which you voluntarily include and transmit online in a publicly accessible blog, forum, social network, or otherwise online may be viewed and used by others. As a general reminder, please think carefully before you decide to put anything on the Internet. For example, if you voluntarily disclose personal information in chat areas or bulletin boards (e.g., comment sections), that information could be seen and used by others, and may result in unsolicited messages from others. We are not responsible for the information you may choose to submit in these public forums. To request removal of your personal information from our blog or community forum, please contact us using the information provided in the section titled Contacting Us. In some cases, for legal retention purposes or technical limitations (e.g., the data may not be searchable), we may not be able to remove personal information voluntarily disclosed by you in such forums, in which case, we will notify you.

With respect to how we use Service Data, we use that information to provide Services to our clients.

HOW WE DISCLOSE YOUR INFORMATION

In addition to using your personal information ourselves, we may send your personal information and other information to other companies, affiliates, and third parties in the following instances:

Service Providers

We may share your personal information with service providers who may use your information to provide us services including, but not limited to: medical diagnostic scheduling, medical consultations, website hosting, data analysis, infrastructure provision, information technology services, conducting surveys and contests, customer service, email or SMS delivery services, payment processing and recouping, auditing, consulting, magazine management and shipping, event management, data security, and anti-fraud monitoring. These service providers have access to personal information that is necessary to perform their functions, and are prohibited from using your personal information for any other purpose.

Corporate Affiliates

We may share personal information with our corporate affiliates and subsidiaries, who process personal information on our behalf as our vendor, where necessary to provide a product or service that you have requested or in other circumstances with your consent or as permitted or required by law.

Business and Advertising Partners

We may share personal information with our business partners, which may include information shared for the purposes of marketing or interest-based advertising. If you provide any user information via an advertiser promotion, please be aware you are directly providing your user information to that advertiser.

We may share certain event registrant user information with sponsors of our live or virtual events (e.g., attendee name, title, company name) or with TheBespoke licensees in circumstances where a licensee works with TheBespoke in the promotion or such an event, subject to applicable law.

For Service Data processed on behalf of our clients, like lead generation data or data collected in connection with a survey conducted for a client, we share the Service Data with our clients.

Legal Compliance and to Defend Our Rights

We may disclose personal information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms and Conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Business Transfers

We may share your personal information and other information with third parties in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of the Company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by the Company about our Properties users is among the assets transferred. In this case, we may notify you if applicable law requires.

Consent

TheBespoke may disclose your Personal Information to third parties with your consent or pursuant to your direction.

DATA SECURITY

We care about the protection of your personal information and use appropriate technical and organizational security measures to do so. These measures are designed to provide a level of security appropriate to the risk of processing of your personal information. 

Your user information is stored on TheBespoke servers located in Canada and United States. We use industry standard physical, electronic, and organizational safeguards to protect your user information against loss or theft as well as unauthorized access and disclosure to protect your privacy. We employ many different security techniques to protect such data from unauthorized access by users inside and outside of the company. We also ensure that, in accordance with good industry practice, we have in place security measures to protect your personal information from interception, including in transit between our different systems and devices. This includes having in place network protection to deny attackers the ability to intercept data and the encryption of your personal information while in transit to deny attackers the ability to read data.

Of course, it’s important to keep in mind that no data transmission on the Internet is guaranteed to be 100% secure. If you are concerned that your privacy may have been breached or that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us as provided below.

DATA RETENTION

We will retain your user information for as long as we have an ongoing legitimate business need to use your user information (for example you have an active medical account with us or to comply with applicable medical data storage, tax, legal, or accounting requirements). When there is no longer such a need, we will delete it or, if this is not possible (for example, because your personal information has been stored in back-up archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. We will also delete certain user information we may retain about you upon your request.

INTEREST-BASED ADVERTISING

Targeted Advertising / Behavioral Advertising

We may ourselves, or with third-party vendors, use personal information to deliver targeted advertising to you when you visit other websites or our Properties (including emails). Cookies, clickstream data, and other similar technologies described above may be used in this process. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising, sometimes called “targeted advertising,” “behavioral advertising,” or “cross-context behavioral advertising,” enables us and our vendors to know your interests in connection with the delivery of that specific ad. We believe that such advertising is helpful because you will see advertisements that are relevant to your interests. We comply with the Self-Regulatory Principles for Online Behavioral Advertising as administered by the Digital Advertising Alliance (DAA). If you would like to opt out of these interest-based advertisements, please follow the opt-out process described below under Your Choices.

Cross Device Matching

We may use information we have collected to help us, or our third-party vendors, determine if you have interacted with our Properties across multiple devices and to match such devices. To accomplish this, we may rely on information (including demographic, geographic, and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies, or we may use information we collect in conjunction with such third-party data. Based on this data, we may then display targeted advertisements across devices that we believe are associated and may provide other services to our advertisers to better enable cross-device targeting and analysis. For further instructions on restricting our use of certain cross-device data, please see Your Choices below.

YOUR CHOICES

Consistent with applicable law, you may exercise the options described in this section regarding your choices with respect to your personal information and communications from us. You may also have certain additional rights available depending on your state or country of residence, as described further below.

Rights and Opt-Outs

Registered theBespoke users may at any time change the information stored in their theBespoke affiliated member profile (such as name, password, location, country, and the topics and authors they are following) by visiting their member profile page. You may also request to delete or modify your personal account and/or any personal information you may have voluntarily submitted to us (e.g., information that you provide to register for a TheBespoke event) if you wish to do so, provided we are able to verify your identity in accordance with applicable law.

You may also ask to opt out of direct email marketing and SMS communications from TheBespoke by following the unsubscribe instructions contained in the communication you have received. For marketing emails, this is typically through an “unsubscribe” or “opt-out” link. To opt out of other forms of marketing, please contact us using the information provided in the section titled Contacting Us below.

Cookies, Tracking, and Interest-Based Advertising

If you would like to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our Properties or some of the functionality may be affected.

The online advertising industry provides a service through which you may opt out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs. You can opt out of targeted advertising from certain providers that participate in the Digital Advertising Alliance (DAA) program at www.aboutads.info/consumers. Other providers are members of the Network Advertising Initiative, and you can opt out of interest-based advertising by those members by visiting http://optout.networkadvertising.org/. Please note that by opting out, you may continue to see generic advertising that is not tailored to your specific interests and activities.

Cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device, and if you opt out on one of your devices, that opt out may not be effective on all of your devices.

For targeted advertisements delivered through mobile apps, you can install the DAA’s AppChoices app on your device to opt out of targeted advertising by certain providers, and can also select a system-level advertising preference on your device (such as “Limit Ad Tracking” on Apple devices or “Opt-out of Interest-Based Ads” on Android devices).

Do Not Track

While some browsers have a “do not track” (also known as DNT) feature that lets you instruct websites not to track your online activities, we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

CROSS-BORDER DATA TRANSFERS

If you submit personal information to TheBespoke, your personal information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. By submitting your personal information to us you agree to the transfer, storage, and processing of your personal information in a country other than your country of residence including, but not necessarily limited to, the United States. Please note that personal information transferred to the United States is subject to access by law enforcement.

LAW ENFORCEMENT REQUESTS

TheBespoke takes the protection of your personal information very seriously and is committed to acting as a responsible data custodian. If we become aware that any law enforcement, regulatory, judicial or governmental authority (“Authority”) wishes to obtain access to, or a copy of, the personal information that we hold about you (whether on a voluntary or mandatory basis) (a “Request”), then we commit to the following: (1) we will investigate the Request before responding, to ensure that it is a valid request made under applicable law; and (2) we will only disclose personal information to the Authority in response to the Request where we are legally required to do so and in accordance with applicable lawful process. The only exception to these commitments is where we reasonably believe (in good faith) that the urgent provision of the requested personal information per the Authority’s Request is necessary to prevent an imminent risk of serious harm to any individual. However, in any event, we shall never knowingly disclose personal information in a massive, disproportionate, or indiscriminate manner, which goes beyond what is necessary in a democratic society.

CHILDREN’S PRIVACY

The Properties are intended for people who are at least 16 years of age. If you are less than 16 years old, please do not send any personal information to us—including information such as your name, address, or email address. We do not knowingly collect (nor do we wish to collect) any personal information from children under the age of 16. If we learn we have collected any personal information from a child under the age of 16, we will delete that information from our database and terminate the corresponding account, if any. We encourage you to discuss the Properties with your parent or guardian.

CHANGES TO THIS POLICY

We may update this Privacy Statement from time to time in response to changing legal, technical or business developments. This Privacy Statement describes our data handling practices for the 12 months prior to the date on which it was last updated. We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Statement at any time, provided that any such modifications will only be applied prospectively. We encourage you to periodically review the Site for the latest information on our privacy practices. Your continued use of the Properties following the posting of any changes to this Privacy Statement means you accept such changes.

CONTACTING US If you have any other questions regarding this Privacy Statement or how to remove or modify your user information or related consents, please feel free to contact us. ATTN:  Privacy Team – Customer Service, at contactbespoke@thebespoke.group

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