PRIVACY POLICY

1. PURPOSE

While you use our website, we are processing your Personal Information. You have the right to know what we do with it and the choices you have over your Personal Information.

This Privacy Policy covers how Lion’s Den or a Lion’s Den - affiliated company (collectively, “LD”) handles personal data whether you interact with us on our websites, or in person. LD’s Privacy Policy does not apply to how third parties define personal data or how they use it. We encourage you to read their privacy policies and know your privacy rights before interacting with them.

2. DEFINITIONS

This Privacy Policy (or "Policy") is addressed to all US residents whose Personal Information we are processing while you use our website. In this Privacy Policy:

• When we say “we”, “us” and “our”, we are referring to LD because we determine the manner of and purposes for processing your Personal Information, and we are responsible for ensuring we do so in compliance with applicable regulations.
• When we say “you”, “user” or “individual(s)”, we are referring to the person accessing our website and the person whose Personal Information we are collecting, using and disclosing.
• When we say “processing”, we are referring to the collection, use or disclosure of your Personal Information.
• When we say, “service providers”, we are referring to organizations that process your Personal Information on our behalf.

If you have any questions or concerns about this Policy, please feel free to contact us at privacy@lionsdens.com or to our toll-free number: 800.345.3308.

In this Privacy Policy, we will tell you:

• What Personal Information do we collect and in what circumstances do we collect it.
• The purposes for which we collect and use your Personal Information.
• The categories of organizations to whom we may disclose your Personal Information.
• What are your rights and how you can exercise them.
• How we secure your information.
• Links to third-party websites and services.
• What happens if we make any change to this Privacy Policy.

While you use our website, we are processing your Personal Information. You have the right to know what we do with it and the choices you have over your Personal Information.

This Privacy Policy (or "Policy") is addressed to all US residents whose Personal Information we are processing while you use our website. In this Privacy Policy:

• When we say “we”, “us” and “our”, we are referring to Lion’s Den because we determine the manner of and purposes for processing your Personal Information, and we are responsible for ensuring we do so in compliance with applicable regulations;
• When we say “you”, “user” or “individual(s)”, we are referring to the person accessing our website and the person whose Personal Information we are collecting, using and disclosing.
• When we say “processing”, we are referring to the collection, use or disclosure of your Personal Information;
• When we say “service providers”, we are referring to organizations that process your Personal Information on our behalf.

If you have any questions or concerns about this Policy, please feel free to contact us at privacy@lionsdens.com or to our toll-free number: 800.345.3308 x752.

In this Privacy Policy, we will tell you:

• What Personal Information we are collecting and in what circumstances we collect it;
• The purposes for which we collect and use your Personal Information;
• The categories of organizations to whom we may disclose your Personal Information;
• What are your rights and how you can exercise them;
• What happens if we make any change to this Privacy Policy.

We collect your Personal Information under the following circumstances:

• You provide it to us directly.
• From Third Parties; or
• We collect it by using automated means.

3.1 THE PERSONAL INFORMATION YOU PROVIDE US DIRECTLY

In short: The types of information we collect about you depends on your use of our products, services and the ways you interact with us. For example, we collect Personal Information when you contact our customer service, sign up to your newsletter, become a member of LD rewards, or enter our contests. The Personal Information we collect may vary whether you purchase products and services from us, or if you are a member, or a simple user of our website.

In detail: The Personal Information you provide to us directly are the following:

• Identifiers and profile information, i.e., real name, alias, online identifier, IP address, email address.
• Demographic information, e.g., postal address, province, country of residence, telephone number.
• Sensitive information, i.e., sexual orientation and preferences.
• Engagement information, such as information on products and services that you purchase, or the promotional offers that you participate in, information relating to your purchase history, and to your commercial relationship with us.
• User Content, such as content of communications, suggestions, questions, comments, feedback, and other information you send to us, that you provide to us when you contact us, or that you post on our website.

3.2. Personal Information from third parties

We also obtain information from third-party sources. We protect information obtained from third parties according to the privacy practices as described in this Privacy Statement. These third-party sources can change, and may include:

• Communication services, including email providers and social networks, when you give permission to access your information on such third-party services or networks.
• Partners with which we offer co-branded products or services or engage in joint-marketing activities.
• Publicly available sources such as open government databases.

3.3. Personal Information we collect automatically when you use our website

In short: During each of your visits on our website, we collect information about you via automated means, such as embedded scripts, web beacons, and cookies (“tracking technologies”). For example, cookies are small text files that are placed on your computer or mobile applications by websites that you visit. They are widely used in order to make websites work, and to provide organizations with information on you and on your browsing activities.

In detail: Cookies and other tracking technologies give us access to the following personal information: i) Identifiers of the equipment you use (IP address of your computer), ii) type of operating system, iii) type and version of the browser software, iv) dates and times of connection to our services, v) address of the originating Internet page ("referrer"), vi) browsing data on our services, content viewed;, vii) information relating to your use of our sites, and viii) information relating to the presence of cookies on your terminal.

Cookies can be implemented by us and also by third-party organizations that are our service providers (for example Google sets a cookie to help us measure our audience).

On your first visit to our website or our platform, a cookie banner is displayed, explaining the categories of Personal Information that we collect, and the purposes for which the data is used, with a link to this Privacy policy.  You will also be given an opportunity to opt-out of the implementation of cookies on your terminal, and your choice is automatically taken into account without any further action being necessary.

We collect your Personal Information under the following circumstances:

• You provide it to us directly; or
• We collect it by using automated means.

 1.1. The Personal Information you provide us directly

In short: During the various interactions we have with you, you may be required to provide us with Personal Information. For example, we collect Personal Information when you contact our customer service, sign up to your newsletter, apply to a job, become a member of LD rewards, or enter our contests. The Personal Information we collect may vary whether you purchase products and services from us, or if you are a member, or a simple user of our website.

In detail: The Personal Information you provide to us directly are the following:

• Identifiers and profile information, i.e., real name, alias, online identifier, IP address, email address;
• Demographic information, i.e., postal address, province, country of residence, telephone number.
• Sensitive information, i.e., sexual orientation and preferences ;
• Engagement information, such as information on products and services that you purchase, or the promotional offers that you participate in, information relating to your purchase history, and to your commercial relationship with us;
• User Content, such as content of communications, suggestions, questions, comments, feedback, and other information you send to us, that you provide to us when you contact us, or that you post on our website.

1.2. Personal information we collect automatically when you use our website

In short: During each of your visits on our website, we collect information about you via automated means, such as embedded scripts, web beacons, and cookies (“tracking technologies”). For example, cookies are small text files that are placed on your computer or mobile applications by websites that you visit. They are widely used in order to make websites work, and to provide organizations with information on you and on your browsing activities.

In detail: Cookies and other tracking technologies give us access to the following personal information: i) Identifiers of the equipment you use (IP address of your computer), ii) type of operating system, iii) type and version of the browser software, iv) dates and times of connection to our services, v) address of the originating Internet page ("referrer"), vi) browsing data on our services, content viewed;, vii) information relating to your use of our sites, and viii) information relating to the presence of cookies on your terminal.

Cookies can be implemented by us and also by third-party organizations that are our service providers (for example Google sets a cookie to help us measure our audience).

On your first visit on our website or our platform, a cookie banner is displayed, explaining the categories of Personal Information that we collect, and the purposes for which the data is used, with a link to this Privacy policy.  You will also be given an opportunity to opt-out of the implementation of cookies on your terminal, and your choice is automatically taken into account without any further action being necessary.

In short: We collect Personal Information for business or commercial purposes.

In detail: We must have a pre-defined objective (purpose) to collect your Personal Information. We process your Personal Information for the following purposes.

• Business purposes:
  • Auditing our interactions with you (counting ad impressions to unique visitors, verifying positioning and quality of ad impressions);
  • Security (detecting security incidents, protecting against malicious or fraudulent activity, and prosecuting offenders);
  • To debug and repair our system;
  • Performing our services (either by us or by our service provider, e.g., maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payment);
  • Internal Research for Tech Development, e.g., carrying out consumer satisfaction surveys;
  • Quality and Safety Maintenance and Verification (improvement, upgrade or enhancement of the service or device owned, manufactured); and
  • Management of unpaid bills and disputes;
• Commercial purposes:
  • Sending of information on our activity, on our publications;
  • Sending of marketing, advertising and promotional offers relating to our products and services by e-mail;
  • Personalized customer loyalty or prospecting actions;
  • Setting up of contests or other promotional operations;
  • Collection of customer opinions;
  • Development of trade statistics; and
  • Setting up of contests or other promotional or event operations with commercial partners.
• Other purposes:
  • To verify your identity and for fraud detection; and
  • To meet our legal obligations;

In short: We collect Personal Information for business or commercial purposes.

In detail: We must have a pre-defined objective to collect your Personal Information.We process your Personal Information for the following purposes.

• Business purposes:
  • Auditing our interactions with you (counting ad impressions to unique visitors, verifying positioning and quality of ad impressions);
  • Security (detecting security incidents, protecting against malicious or fraudulent activity, and prosecuting offenders);
  • To debug and repair our system;
  • Performing our services (either by us or by our service provider, e.g., maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payment);
  • Internal Research for Tech Development, e.g., carrying out consumer satisfaction surveys;
  • Quality and Safety Maintenance and Verification (improvement, upgrade or enhancement of the service or device owned, manufactured); and
  • Management of unpaid bills and disputes;

• Commercial purposes:
  • Sending of information on our activity, on our publications;
  • Sending of marketing, advertising and promotional offers relating to our products and services by e-mail;
  • Personalized customer loyalty or prospecting actions;
  • Setting up of contests or other promotional operations;
  • Collection of customer opinions;
  • Development of trade statistics; and
  • Setting up of contests or other promotional or event operations with commercial partners.
• Other purposes:
  • To verify your identity and for fraud detection; and

To meet our legal obligations

In short: In certain circumstances, we may disclose your Personal Information to external organizations (e.g., our service providers, our business partners…) or public authorities. We do not sell, rent or disclose your Personal Information to any third party if you choose to opt-out from that sale.

In detail: We have disclosed your Personal Information to the categories of recipients listed below in the past 12 months:

5.1 Disclosure for Business purposes:

In the preceding twelve (12) months, we have shared your Personal Information to following categories of service providers:

• data analytics providers; and
• operating systems and platforms.

5.2 Disclosure for commercial purposes:

In the preceding twelve (12) months, we have share your Personal Information to the following categories of third parties.

• advertising networks;
• marketing partners and business affiliates; and
• data analytics providers.

If you decide to subscribe to the products or services of our business partners and you allow them to access some of your information, in particular by logging into their sites or applications, their privacy policies will be applicable to you.

We have no control over the collection, use and disclosure of your information when carried out by our business partners on their own website.

5.3 Public authorities, judicial or administrative authorities

We may disclose your Personal Information when we are required or authorized by law to cooperate with local, national or international law enforcement or other authorities for the reporting of and/or investigation of improper or unlawful activities, or if we need to comply with court orders.

In short: In certain circumstances, we disclose your Personal Information to external organizations (e.g., our service providers, our business partners…) or public authorities. We do not sell, rent or disclose your Personal Information to any third party if you choose to opt-out from that sale.

In detail: We have disclosed your Personal Information to the categories of recipients listed below in the past 12 months:

• Disclosure for Business purposes:

In the preceding twelve (12) months, we have shared your Personal Information to following categories of service providers:

• data analytics providers; and
• operating systems and platforms.
• Disclosure for commercial purposes:

In the preceding twelve (12) months, we have sold your Personal Information to the following categories of third parties.

• advertising networks;
• marketing partners and business affiliates; and
• data analytics providers.

If you decide to subscribe to the products or services of our business partners and you allow them to access some of your information, in particular by logging into their sites or applications, their privacy policies will be applicable to you.

We have no control over the collection, use and disclosure of your information when carried out by our business partners on their own website.

• Public authorities, judicial or administrative authorities

We may disclose your Personal Information when we are required or authorized by law to cooperate with local, national or international law enforcement or other authorities for the reporting of and/or investigation of improper or unlawful activities, or if we need to comply with court orders.

Consumer privacy rights vary depending on where you reside. You may have the following consumer privacy rights under applicable state laws:

• Right to Know: you may have the right to request information about the personal information we have collected about you and for what purpose.
• Right to Access: you may have the right to request information about how we process your personal information and to obtain a copy of that personal information.
• Right to Portability: you may have the right to receive your personal information, in a structured, commonly used, and machine-readable format and to have that information transmitted to another organization in certain circumstances.
• Right to Deletion: you may have the right to request the deletion of your personal information that we have collected from you.
• Right to Be Free from Discrimination: LD will not discriminate against you for exercising your consumer privacy rights. 
• Right to Opt-out of Sharing: you may have the right to opt out of LD sharing your personal information with third parties for some purposes, including sharing that may be defined as a sale under certain laws.
• Right to Make Choices About Email Marketing: you may have the right to make choices about receiving email marketing.

Please keep in mind that we may not be able to honor all requests, such as if the information is required to process your payments or returns, to fulfill your order, or to comply with tax, audit, or other regulatory requirements.

California residents can also to opt out of the “sale” or sharing of your personal information for each participating browser system that you use or can clicking on the “Do not share my Personal Information” link at the bottom of our webpage for other options. Please keep in mind that these opt-out tools are limited to the device and web browser you are using because they work off your device ID or browser ID. If you use another device or browser, you will need to opt-out on each device and browser. If you block or clear cookies from your browser, it may remove the opt-out settings, requiring you to opt-out again.

6.1 California Residents

The California Consumer Privacy Act (“CCPA”) grants California residents certain rights regarding the personal information that businesses have about them. These include (a) the right to know about personal information categories the business collected about you in the prior 12 months, the source of such information, the purpose for collecting the information and the specific information collected about you (this information is available in our Supplementary Disclosures; (b) the right to request access or deletion of your personal information, (c) the right to request correction of your personal information as well as (d) the right to direct a business to stop sharing your personal information. LD may be categorized as a “Service Provider” under the CCPA in certain cases, such as in providing products and services to our customers. In other cases, LD may be categorized as a business, such as in our day to day operations. The categories of third parties to whom personal information is disclosed include advertisers and marketing partners and data analytics providers. The categories of information we may share with such parties may include device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history; location information, such as city; and inference data. To opt out, please click the “Do Not Share My Personal Information” button at the bottom of our webpage, or you or an authorized agent acting on your behalf (subject to our verification of the identity and legal authority associated with such request as required by law) can also send your request to us at the address listed in section 10 of this policy.

6.2 Colorado Consumers

The Colorado Privacy Act (“CPA”) grants consumers that are residents of the State of Colorado certain rights provided by C.R.S. § 6-1-1-1306 regarding the personal information businesses have about them, subject to certain limitations. These rights are listed in more detail below, and at this time do not extend to individuals acting in commercial or employment contexts.

The Right of Access: Consumers have the right to confirm the processing of their personal data and to access their personal information, and obtain a copy of it in a readily useable format (to the extent “technically feasible”);

The Right to Correct Inaccuracies: Consumers may request that inaccuracies in their personal information are corrected, considering the nature of the data and the business’ purposes in using it;

The right to Deletion:  Consumers have the right to delete personal information concerning the consumer;

The Right to Data Portability: Consumers have the right to obtain a copy of their data from the controller (LD) in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity up to twice per year;

The Right to Opt-Out: Consumers have the right to opt out of several different uses of their personal information, including: targeted advertising, sale of their personal information, and profiling for the purpose of making decisions with legal or similarly significant effects concerning the consumers. For other opt-outs or requests, please contact us at cs@lionsden.com or write to us at the address listed in section 10 of this policy.

 The categories of third parties to whom personal information is disclosed include advertisers and marketing partners and data analytics providers.  The categories of information we may share with such parties may include device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history; location information, such as city; and inference data.  To opt out, please click the “Do Not Share My Personal Information” button at the bottom of our webpage, or you or an authorized agent acting on your behalf (subject to our verification of the identity and legal authority associated with such request as required by law) can also send your request to us at the address listed in section 10 of this policy.

A Colorado resident may also designate another person to act on their behalf as their authorized agent with respect to these rights.  We will seek to authenticate that someone claiming to be an authorized agent on behalf of another is in fact an authorized agent for that individual.  While this may vary on a case-by-case basis, some ways we may seek to authenticate an authorized agent is by requesting a power of attorney or other legal document that reflects this relationship.

Colorado residents may appeal LD’s response to their requests by sending an email to cs@lionsden.com or by contacting us at our address noted above.

6.3 Connecticut Residents

The Connecticut Data Privacy Act or (“CTDPA”) provides Connecticut residents with certain rights.  At this time, it does not apply to employees or to business-to-business relationships.  Connecticut residents the following rights:

The right to access personal data that a controller has collected about them.

The right to correct inaccuracies in their personal data.

The right to delete their personal data, including personal data that a controller collected through third parties.

The right to obtain a copy of their personal data in a portable and readily usable format that allows them to transfer the data to another controller with ease.

The right to opt-out of:

• the sale of their personal data;
• the processing of personal data for the purposes of targeted advertising; and
• profiling that may have a legal or other significant impact.

A Connecticut resident may also designate another person to act on their behalf with respect to these rights.

The categories of third parties to whom personal information is disclosed include advertisers and marketing partners and data analytics providers.  The categories of information we may share with such parties may include device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history; location information, such as city; and inference data.  To opt out, please click the “Do Not Share My Personal Information” button at the bottom of our webpage, or you or an authorized agent acting on your behalf (subject to our verification of the identity and legal authority associated with such request as required by law) can also send your request to us at the address listed in section 10 of this policy.

6.4 Virginia Consumers

The Virginia Consumer Data Protection Act (“VCDPA”) grants consumers that are residents of the Commonwealth of Virginia certain rights regarding the personal information businesses have about them, subject to certain limitations. These rights are listed in more detail below, and at this time do not extend to individuals acting in commercial or employment contexts.

The Right to Know: Consumers have the right to know whether or not a business processes their personal information;

The Right of Access: Consumers have the right to access their personal information, and obtain a copy of it in a readily useable format (to the extent “technically feasible”);

The Right to Correct Inaccuracies: Consumers may request that inaccuracies in their personal information are corrected, considering the nature of the data and the business’ purposes in using it;

The Right to Data Portability: Consumers have the right to obtain a copy of their data from the controller (LD) in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller;

The Right to Opt-Out: Consumers have the right to opt out of several different uses of their personal information, including: targeted advertising, sale of their personal information and profiling for the purpose of making decisions with legal or similarly significant effects concerning the consumers. To opt out of targeted advertising online, please adjust your cookies settings to reject marketing cookies as described in LD’s Cookie Notice. For other opt-outs or requests, please contact us at cs@lionsden.com or write to us at the address listed in section 10 of this policy.

In short: Subject to certain exceptions and restrictions, you have the right to ask us to delete your Personal Information, or to provide you with information on the Personal Information that we have collected, our sources of collection, the business and commercial purposes for which this information was collected, and the categories of third parties with whom this information has been shared.

In detail: If you are a US resident and wish to exercise these rights, please contact our customer service at cs@lionsden.com or to our toll-free number: 800.345.3308

Making a verifiable request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request. To initially verify your identity, we will use the following Personal Information: Name, email, phone number, IP address, dates of use, usage information, your LD rewards membership, your online account.

If we cannot initially verify your identity, we may request additional information to complete the verification process, such as email address, phone number, state or government issue ID or utility bill.

You may designate an authorized agent to exercise your rights on your behalf. We may ask you or the agent to provide proof that the agent has received your authorization to act on your behalf, such as a written and duly signed certificate stating you authorize the agent to act on your behalf.

We will respond to your request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

In short: Subject to certain exceptions and restrictions, you have the right to ask us to delete your Personal Information, or to provide you with information on the Personal Information that we have collected, our sources of collection, the business and commercial purposes for which this information was collected, and the categories of third parties with whom this information has been shared.

In detail: If you are a US resident and wish to exercise these rights, please contact our customer service at cs@lionsden.com or to our toll-free number: 800.345.3308

Making a verifiable request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request. To initially verify your identity, we will use the following Personal Information: Name, email, phone number, IP address, dates of use, usage information, your LD rewards membership, your online account.

If we cannot initially verify your identity, we may request additional information to complete the verification process, such as email address, phone number, state or government issue ID or utility bill.

You may designate an authorized agent to exercise your rights on your behalf. We may ask you or the agent to provide proof that the agent has received your authorization to act on your behalf, such as a written and duly signed certificate stating you authorize the agent to act on your behalf.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

7.1 How can you ask us not to Share your Personal Information?

In short: As explained above in our Privacy policy, we do not and will not share any Personal Information to third parties for marketing or any other parties for commercial purposes without your consent. You can object to such sale of your Personal Information.

In detail: You can opt out of the sale of your Personal Information Personal Information by clicking on the “Do not share my Personal Information” link (link to add here).

We will not discriminate you in case you decide to exercise your rights, which means that we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services;
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Even after you opt out from receiving promotional messages from us, you may continue to receive transactional and product-related messages from us regarding our services.

In short: As explained above in our Privacy policy, we do not and will not sell any Personal Information to third parties for marketing or any other parties for commercial purposes without your consent. You can object to such sale of your Personal Information.

In detail: You can opt out of the sale of your Personal Information Personal Information by clicking on the “Do not sell my Personal Information” link (link to add here). We will stop the sale of your Personal Information no later than 15 days following your request.

We will not discriminate you in case you decide to exercise your rights, which means that we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services;
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

With respect to the right to opt-out from receiving promotional communications from us, please allow ten (10) business days for your request to be processed. Even after you opt out from receiving promotional messages from us, you may continue to receive transactional and product-related messages from us regarding our services.

We use appropriate technical, organizational, and physical data security safeguards to help protect against unauthorized access to, use or disclosure of your personal information, such as:

• Using encryption when collecting or transferring sensitive information, such as credit card details.
• Designing our data security safeguards to ensure the ongoing security, integrity, availability and resilience of processing systems and services.
• Limiting access to the information we collect about you.
• Ensuring that our Business Partners have appropriate safeguards in place to help protect your personal information.
• As required by law, destroying or de-identifying personal information.

We encourage you to keep any passwords you use confidential and to be careful to avoid “phishing” scams where someone may send you an email that appears to be from LD asking for your personal information.  LD will not request your ID or password through email. 

We may sometimes provide links directing you to websites operated by third parties. Those websites may also collect your personal information, subject to the third party’s information practices as outlined in their privacy statements. LD does not operate these websites and is not responsible for their information practices. We encourage you to review privacy statements on any third-party website before providing any personal information.

In short: We may update this Policy to reflect changes to our information practices.

In detail: We will post any changes to this page and, if the changes are significant, we will provide a more prominent notice to you. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices and to contact us if you have any questions or concerns.

If you have any questions or concerns about this Policy, please feel free to contact us at  privacy@lionsden.com or at our toll-free number (800.345.3308) or via mail at:

Lion’s Den
C/O Marketing
PO Box 34058
Columbus, Ohio 43234