Privacy Policy

PRIVACY POLICY

Last Updated: February 25 2025

This Privacy Policy (“Policy”) explains how GSJM Events, LLC d/b/a Sugar Sisters (“Sugar Sisters Miami”) collects, uses, and discloses information about you through your access or use of https://www.sugarsistersmiami.com/, or other of our online services that link to this Policy (collectively, the “Services”) or otherwise interact with us. By using our Services, you acknowledge that you have read and understood this Policy. If you obtain your use of the Services in connection with the services offered by a third party, or click on links to and from our website, the individual terms of that third party and its own privacy policy may differ from what is described in this Policy. We encourage you to read the privacy statements and terms and conditions of linked or referenced websites. These third-party websites and apps may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect data or solicit personal information. We are not responsible for the practices of such websites.

Changes to this Policy

We may change this Policy from time to time. If we make any changes to this Policy, we will change the “last updated” date above. We encourage you to check this Policy whenever you use any of Services or otherwise interact with us to understand how your personal information is used and the choices available to you.

COLLECTION OF INFORMATION

We collect information from you in various ways when you use our Services. This may include information defined as personal data, personal information, or personally identifiable information under applicable law (“personal information”). We may also supplement this information with information from other companies and we also collect aggregate data. Aggregate data is information we collect about a group or category of services or users from which individual user identities have been removed. Aggregate data helps us understand trends in our users’ needs so that we can better consider new features or otherwise tailor our Services.

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you register to use our Services or update your account, participate in any interactive features of the Services (such as sending a message), make a purchase, participate in a contest or promotion, apply for a job, request customer support, or otherwise communicate with us. The types of information we may collect include: your name and email address; shipping address; phone number; company name, company title, and other account information you provide; demographic information; information you upload like photos, and in certain instances, your credit card and other payment information.

Other Information We Collect When You Use our Services

When you access or use our Services, we automatically collect information about you, including:

Usage Information: We automatically receive certain types of information when you interact with our Services. For example, it is standard for your web browser to automatically send information to every website you visit, including ours. That information includes your computer’s IP address, access times, your browser type and language, and referring website addresses. We may also collect information about the type of operating system you use, your account activity, and files and pages accessed or used by you.
Transactional Information: When you make a purchase or return, we will collect information about the transaction, such as product details, purchase price, and date and location of the transaction.
Log Information: We collect information related to your access to and use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services
Device and Activity Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information. When using your computer or mobile device with the Services, data recorded on your computer or mobile device about your activity may be transferred from your computer or mobile device to our servers. This data is stored and used to provide the Service and is associated with your account. We also collect information about any rehabilitee protocols you may be using.
Submissions and Company Service: From time to time we may use surveys, contests or sweepstakes requesting personal or demographic information and customer feedback. If you choose to order a product through the Services, you may post a Product review.
Shipping Information. If you choose to order a product through the Services, our payment processing vendor collects your shipping address and other contact details, such as email address and phone number, may also be collected.
Credit Card, Payment Information, and Billing Address: In certain instances, your credit card, payment information and billing address is processed in order for you to purchase a product through the Services. This applies for wholesale purchases and product returns.

Information Collected by Cookies and Similar Tracking Technologies:

We (and our service providers) may also use certain kinds of technology such as cookies and web beacons to collect information. For more information on cookies, please see Section “Use of Cookies” below.

Children’s Privacy

Protecting children’s privacy is important to us. We do not direct our website to, nor do we knowingly collect any personal information from, children under the age of 16. If we learn that a child has provided personal information to our website, we will use reasonable efforts to remove such information from the files of our website. If you think we might have any information from or about a child, please contact us via our contact details in Section “Contact Us.”

USE OF INFORMATION

In general, we use your personal information to process your requests or transactions, to provide you with information or services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to facilitate your use of, and our administration and operation of, the Services and to otherwise serve you and our users. We also use the information we collect to:

Enable you to conduct commercial transactions on the website, purchase and sales management;
Send you a welcome email and to contact you about your use of the Services; to respond to your emails, submissions, comments, requests or complaints; to perform after-sales services; to anticipate and resolve problems with our service; to respond to customer support inquiries, for assistance with our product and service development; and to inform you of updates to products and services from Company that better meet your needs;
Request feedback and to enable us to develop, customize, and improve our Services;
Conduct marketing analysis, monitor, and analyze trends, to send you surveys or newsletters, to contact you about services, products, activities, special events or offers from Company or our partners and for other marketing, informational, product development and promotional purposes, and for profiling purposes, to send you discount codes;
To facilitate contests, sweepstakes, and to contact you if you win a contest;
To detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity and to protect the rights and property of Company and others;
For compliance management;
For other purposes about which we notify you in advance.

DISCLOSURE OF INFORMATION

We will not give, sell, rent, share, or trade any of your personal information with any third party except as outlined in this Policy or with your consent. We may disclose personal information and have legally bound all third-party service providers to appropriate data protection and data security:

With service providers that perform services for us, including to provide the Services to you, including by providing personal information to our third-party payment processors, to original equipment manufacturers of products you order from the website, and other third-party vendors or service providers that have contracted with us to provide the Services to you who need access to such information to carry out work on our behalf and who may use personal information to improve their services;
With service providers who provide fraud detection and prevention services to us;
With third parties to protect Company, agents, customers, and others including to enforce our agreements, policies and terms of use;
With third parties when the Company, in good faith believes, that disclosure is needed to respond to an emergency, or protect the personal safety of any person.
In connection with an acquisition, merger, or sale of all or a substantial portion of our business, with or to another company. In such an event, you will receive notice if your data is transferred and becomes subject to a substantially different privacy policy; Between and among Company and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership;
With local or foreign financial, tax, administrative, criminal or judicial or public authorities or institutions;
With our affiliated companies and other group companies; and
With your consent or at your direction.

The Services may include features that by their nature support disclosure your content (i.e., photos, videos, text) that you upload or post on the Services in a public forum, such as a discussion forum or product reviews. Other users of the Services can see personal information you choose to disclose, such as your location, interests, occupation and birthday; and they can post comments in response to certain of your public submissions.

This Policy in no way restricts or limits our collection and use of fully anonymized data, and we may disclose anonymized data with third parties for various purposes, including to help us better understand our customer needs and improve our Services, to provide new Services and for advertising and marketing purposes.

SOCIAL SHARING FEATURES

The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you disclose actions you take on our Services with other media, and vice versa. Your use of such features enables the disclosure of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

With your consent, we collect personal information processed through social media plugins on our website (e.g., Facebook, Instagram, YouTube, X f/k/a Twitter). More information can be found under Section “Use of Cookies” on cookies. Social networks are able to retrieve personal information through those plugins, even if you do not interact with them. Moreover, if you are logged onto a social network while visiting our website with social plugins imbedded in them, the social network can collect and store information about such visit and link it to your social network user account. We may act as joint controllers with these social media providers, for the processing of personal information in context of insight information. For this purpose, a joint controllership arrangement has been concluded which may be viewed at the following link: https://www.facebook.com/legal/terms/page_controller_addendum. As we have no control over the information once collected and transmitted to social media networks through their plugins, we encourage you to read their applicable privacy policies to learn more about them.

USE OF COOKIES

Our website uses first- and third-party single-session and multi-session cookies, log files and web beacons. A cookie is a small amount of data which is sent to your browser and stored on your computer’s hard drive. Single session cookies last only as long as your web browser is open and are used for technical purposes such as enabling better navigation of our website. Multi-session cookies are stored on your computer for longer periods and are used for purposes including tracking the number of unique users, how much time a user spends on a page, and other web statistics. A web beacon is an electronic image, also called a “gif,” that may be used on our web pages to deliver cookies, count visits, and compile statistics on usage and campaign effectiveness or in our emails to tell if an email has been opened and acted upon.

We may allow others to provide analytics services and serve advertisements on our behalf across the web. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by Company and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices in the United States and http://www.youronlinechoices.eu in the European Union.

You can manage cookies via our cookie banner or on your device according to the settings of your internet browser.

Our system may not respond to Do Not Track requests or headers from some or all browsers. To learn more about the use of cookies or other technologies to deliver more relevant advertising and to know your choices about not having this information used by third-party advertisers, please visit http://www.networkadvertising.org and http://www.aboutads.info/choices/.

DATA RETENTION

We may retain your personal information, including all categories of personal information as described in the “Residents of California” section, for as long as needed to carry out the purposes described herein or as otherwise required by applicable law. Unless we are required or permitted by law to keep your personal information for a longer period of time, when your personal information is no longer necessary to carry out the purposes for which we process it, we will delete your personal information or keep fully anonymized. When determining the retention period, we take into account various criteria, such as the nature of the use of our Services, your general relationship with us, the impact on our ability to provide you Services if we delete your personal information, mandatory retention periods provided by law and the statute of limitations, and our use of your personal information for aggregated market research.

NETWORK AND INFORMATION SECURITY

We take appropriate steps to protect information we collect from you to prevent loss, misuse and unauthorized access, disclosure, alteration, and destruction. The servers on which information is stored are kept in a controlled environment with limited access (e.g., TLS/SSL certificates). It is important that you protect against unauthorized access to your password and computer, be sure to sign off when finished using a shared computer. While we take reasonable efforts to guard personal information, we knowingly collect directly from you, no security system is impenetrable. In addition, we cannot guarantee that any collected personal information you choose to include in the Services are maintained at adequate levels of protection to meet specific needs or obligations you may have relating to that information.

YOUR CHOICES

Account Information

If your personal information changes in any way, we encourage you to update and correct your account information by logging into your account or emailing us at info@sugarsistersmiami.com. If you wish to delete your account, please email us at info@sugarsistersmiami.com but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a limited period of time.

Promotional Communications

Sugar Sisters Miami may send you communications or data regarding our Services taking into account applicable consent requirements, including but not limited to: (i) notices about your use of our Services, including any notices concerning violations of use, (ii) updates, and (iii) promotional information and materials regarding our Services. You may opt-out of receiving promotional emails from Company by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing info@sugarsistersmiami.com with your specific request. Opt-out requests will not apply to transactional service messages, such as security alerts and notices about your current account and Services.

RESIDENTS OF CALIFORNIA

Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act or (“CCPA”) (California Civil Code Section 1798.100 et seq.), as amended by the California Privacy Rights Act (“CPRA”) (Civil Code Section 1798.100, et seq.) (collectively, “California Law”) and the “Shine the Light” Law (California Civil Code Section 1798.83). If you are a California resident, this section applies to you.

These rights include:

Right to Know/Access. You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and verify your request, we will disclose to you: the categories of personal information we collected about you; the categories of sources for the personal information we collected about you; our business or commercial purpose for collecting, disclosing, selling or sharing that personal information; the categories of third parties with whom we disclosed, shared or sold that personal information; and the specific pieces of personal information we collected about you (also called a data portability request). You may only make a Right to Access request twice within a 12-month period.
Right to Delete. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and, where required, direct our service providers, contractors, and third parties to whom we have sold or shared your personal information to delete) your personal information from our records, unless an exception under California Law applies.

We may deny your deletion request if retaining the information is necessary for us (or our service provider(s) or contractor(s)) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you (e.g., we may deny your deletion request if you have chosen to participate in our warranty program).
Help ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided for by law.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of information is likely to render impossible or seriously impair the achievement of such research, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation (including complying with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.)).
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Opt-Out of the Sales and Sharing of Personal Information: We do not, and will not, sell the personal information of our customers for direct, monetary profit. However, we may sell or share-as those terms are defined under California Law-your personal information with certain third parties. You have the right to opt out of the selling or sharing of your personal information. Once you make a verified opt-out request, we will wait at least 12 months before asking you to reauthorize personal information sharing. However, if at a later time, you wish to allow us to sell share your personal information, you must opt into such selling or sharing, and may do so by contacting us as described in Section “Contact Us.” If a transaction requires the selling or sharing of your personal information in order to complete the transaction, we will notify you and provide instructions on how you can opt in.
Right to Correct Inaccurate Personal Information: You have the right to request that we correct any inaccuracies in the personal information that we maintain about you.
Right to Non-Discrimination or Retaliation: Unless permitted by applicable law, we will not retaliate or discriminate against you for exercising any of your privacy rights under California or applicable law, including by denying you goods or services; charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing you a different level of quality of goods or services; or suggesting that you will receive a different price or rate for goods or services or a different level of quality of goods or services.

Additional Disclosures Related to the Collection, Use, and Disclosure of Personal Information.

Collection and Use of Personal Information: In the preceding 12 months, we have collected the following categories of personal information directly from you, automatically when you use the Services or from other third-party sources, such as publicly-available sources and databases, in accordance with applicable law: identifiers, characteristics of protected classifications under California or U.S. law, commercial information, internet and electronic network activity, geolocation data, audio and visual information, inferences drawn about your preferences, and other categories of personal information that relates to or is reasonably capable of being associated with you.

Disclosures, Sales and Sharing of Personal Information:

Disclosures: In the preceding 12 months, we have disclosed the personal information categories identified in the “Collection and Use of Information” section above to the following categories of third parties for a business or commercial purpose:
Internally: We may disclose your personal information to our affiliates, business partners, employees and other parties who require such information to assist us with establishing, maintain and managing our business relationship with you.
Service Providers or Contractors: We many disclose your personal information to our service providers or contractors (including third-party hosting providers and payment processors) that provide services on our behalf, such as for email marketing, data analytics, newsletters, notice and other communications, or that assist us in monitoring, improving and hosting the Services.
In the Event of a Business Transaction: If we are exploring or go through a business transition or financial transaction, such as a merger, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, securities offering, or sale of all or a portion of our assets, we may disclose your personal information to a party or parties in connection with exploring or concluding such transaction.
For Legal Purposes: We disclose your personal information when we think it is necessary to investigate or prevent actual or expected fraud, criminal activity, injury or damage to us or others; when otherwise required by law, regulation, subpoena, court order, warrant or similar legal process; or if necessary to assert or protect our rights or assets.
With Your Consent or Authorization: To anyone for whom you have authorized disclosure of information in this Policy.
Other: We may disclose your personal information to any other third party for such purposes as disclosed by us in this Policy or when you provide your information.
Sales and Sharing. The Company does not, and will not, sell personal information of our customers for direct, monetary profit. However, we may sell or share-as that term is defined under California Law-your personal information with certain third parties. In the preceding 12 months, we have sold or shared the following categories of personal information:
Right to Delete. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and, where required, direct our service providers, contractors, and third parties to whom we have sold or shared your personal information to delete) your personal information from our records, unless an exception under California Law applies.

We may deny your deletion request if retaining the information is necessary for us (or our service provider(s) or contractor(s)) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you (e.g., we may deny your deletion request if you have chosen to participate in our warranty program).
Help ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided for by law.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of information is likely to render impossible or seriously impair the achievement of such research, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation (including complying with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.)).
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Opt-Out of the Sales and Sharing of Personal Information: We do not, and will not, sell the personal information of our customers for direct, monetary profit. However, we may sell or share-as those terms are defined under California Law-your personal information with certain third parties. You have the right to opt out of the selling or sharing of your personal information. Once you make a verified opt-out request, we will wait at least 12 months before asking you to reauthorize personal information sharing. However, if at a later time, you wish to allow us to sell share your personal information, you must opt into such selling or sharing, and may do so by contacting us as described in Section “Contact Us.” If a transaction requires the selling or sharing of your personal information in order to complete the transaction, we will notify you and provide instructions on how you can opt in.
Right to Correct Inaccurate Personal Information: You have the right to request that we correct any inaccuracies in the personal information that we maintain about you.
Right to Non-Discrimination or Retaliation: Unless permitted by applicable law, we will not retaliate or discriminate against you for exercising any of your privacy rights under California or applicable law, including by denying you goods or services; charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing you a different level of quality of goods or services; or suggesting that you will receive a different price or rate for goods or services or a different level of quality of goods or services.

Category

Business or Commercial Purpose

Categories of Third Parties to Whom Personal Information was Disclosed That May be Considered “Sharing” Under California Law

Identifiers

To provide you with personal advertising and content

- Advertisers and advertising networks - Business partners or affiliates

Internet or other similar network activity

To provide you with personal advertising and content

- Advertisers and advertising networks - Business partners or affiliates

We do not knowingly sell or share the personal information of consumers under 16 years of age.

Exercising Your Rights as a Resident of California

If you are a California resident and would like to exercise any of your privacy rights as described in this section, please submit a request to us by emailing us at info@sugarsistersmiami.com.

If you have a valid opt-out preference signal enabled (e.g., Global Privacy Control), you will automatically be opted out of the sale or sharing of your information, but we may ask you to confirm your preference if you have previously consented to the sale or sharing of your personal information. Please also note that that if you are not logged into your account, we may not be able to associate the browser or device information connected to your opt-out preference signal with you. If you would like for us to make this connection, you may submit additional information to us through the interactive webform linked above and in the “Do Not Sell or Share My Personal Information” link at the bottom of our website.

To download and use a browser supporting the opt-out preference signal, please visit https://globalprivacycontrol.org/orgs. If you choose to you the opt-out preference signal, you will need to enable it for each supported browser or browser extension you use.

To exercise your right to access, delete or correct your personal information as described above, we need to verify your identity or authority to make the request and confirm the personal information relates to you. To verify your identity, we may ask you to provide your full name, telephone number, and address.

Only you or an authorized agent (“Authorized Agent”) may make a verifiable consumer request related to your personal information. You also may make a verifiable consumer request on behalf of your minor child. When an Authorized Agent is submitting a request on your behalf, we may require your Authorized Agent to provide evidence of their entitlement, which may include information sufficient to identify you and the purpose of the request, and at least one of the following:

Written and signed permission designating the Authorized Agent to act on your behalf. You must verify your identity with us and directly confirm with us that you have provided the Authorized Agent permission to submit the request;
Evidence that you have provided the Authorized Agent with power of attorney pursuant to the California Probate Code; or
Proof that the Authorized Agent is a person or business entity registered with the California Secretary of State and that you have authorized such person or business entity to act on your behalf.

Absent such documentation, we reserve the right to refuse to comply with third-party requests for information.

Non-affiliated third parties are independent from us and, if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.

Shine the Light

California Civil Code Section 1798.83 gives you the right, if a California resident, to request certain details about how their information is disclosed to third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us as described in Section “Contact Us.”

RESIDENTS OF COLORADO, CONNECTICUT, UTAH, AND VIRGINIA

For eligible residents of Colorado, Connecticut, Utah and Virginia, you also have rights with respect to the personal information, also known as personal data, that we collect about you. This Colorado, Connecticut, Utah, and Virginia Privacy Rights section supplements this Privacy Policy and applies solely to eligible residents of Colorado, Connecticut, Utah and Virginia. Any terms not defined in this section have the same meaning as defined under applicable Colorado, Connecticut, Utah and Virginia privacy law, including the Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act and Virginia Consumer Data Protection Act. Subject to certain exceptions, if you are an eligible resident of one of these states, you have certain privacy rights which may include, depending on your state of residency:

Right to Access. You have the right to confirm whether the Company processes your personal information and the right to access such personal information. You also have the right to obtain your personal information in a portable, and to the extent reasonable feasible, readily usable format that you can transmit without hinderance.
Right to Delete. You have the right to request that the Company delete the personal information you have provided to us or that the Company has otherwise obtained about you.
Right to Correct. Except for residents of Utah, you have the right to request that the Company correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.
Right to Opt Out. You have the right to opt out of the processing of your personal information for the purposes of: (i) targeted advertising, (ii) the sale of your personal information and (iii) except for residents of Utah, profiling in furtherance of decisions, including, for eligible residents of Connecticut, solely automated decisions, that produce legal or similarly significant effects.
Right to Appeal. Except for residents of Utah, you have the right to appeal the Company’s decision with regard to your request to exercise any rights described herein.

You do not need to create an account with us to exercise your Colorado, Connecticut, Utah and Virginia privacy law rights. If you would like to exercise the rights described in this section, including the right to opt out, please submit a request to us by emailing us at info@sugarsistersmiami.com.

ADDITIONAL INFORMATION FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area or Switzerland, you have certain rights and protections under the law regarding the processing of your personal information.

Legal Basis

Purpose

Performance of a contract to which you are a party or precontractual measures taken at your request.

Provision of Services, including the warranty and to respond to your requests and to assist you.

To fulfil our legitimate business interest (to the extent it does not infringe on any individual’s fundamental rights and freedoms)

To improve our Services, to personalize and improve your experience, to enable and promote our Services, to protect the integrity of our website and our Services, to protect and manage legal claims and defend our position in the event of proceedings; to enhance cyber security, manage our platforms and websites and ensure business continuity; to notify you of changes to our Services, to conduct marketing analysis, monitor and analyze trends, to manage customer relationships and accounts, including contests and to send marketing communications and for profiling purposes, to send you discount codes. If you are a customer and unless you object, we may send you offers and marketing materials for our products and services that are similar to those you have already purchased or are subscribed to.

Subject to applicable law and regulations, in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, to transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal information that you provide and other information concerning your relationship with us.

To comply with legal and regulatory obligations.

To comply with legal and regulatory obligations such as the prevention of fraud and money laundering.

Your consent

To send any marketing communications if you are not yet a customer, or for products and services different from those you have purchased or subscribed to, or for products and services from our trusted partners and to use certain cookies for commercial purposes or to enhance the knowledge of your account.

Transfers to the U.S. and other countries

To provide the Services, we may transfer your information to our servers in the United States, and possibly to other countries. When we transfer information from the European Economic Area (“EEA”) to countries that have not been deemed to provide an adequate level of protection, we will either rely on a derogation applicable to the specific situation, or we employ data processing agreements based on the EU Standard Contractual Clauses to help ensure that your data is protected wherever it is transferred. You may request a copy of these clauses by contacting us at info@sugarsistersmiami.com.

We comply with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the United Kingdom extension to the EU-U.S. DPF (“UK Extension”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. DPF Principles, the UK Extension and the Swiss-U.S. DPF Principles with regard to the processing of personal data received from the European Union, the United Kingdom and/or Switzerland in reliance on the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF respectively. If there is any conflict between this Policy and the EU-U.S. DPF Principles, the UK Extension, and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF Principles, the UK Extension and the Swiss-U.S. DPF Principles, we are committed to resolving complaints about our processing of your personal information. EU, UK and Swiss individuals with inquiries or complaints regarding our compliance should first contact us. We have further committed to refer unresolved complaints to the International Centre for Dispute Resolution - American Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.icdr.org/dpf for more information or to file a complaint. The services of the International Centre for Dispute Resolution - American Arbitration Association are provided at no cost to you.

Under certain conditions, you may be able to invoke binding arbitration to resolve your complaint. Company is subject to the investigatory and enforcement powers of the Federal Trade Commission. If we disclose personal information transferred to the U.S. under the EU-U.S. DPF, the UK Extension, or the Swiss-U.S. DPF with a third-party service provider that processes such data on our behalf, then we will be liable for that third party’s processing in violation of the EU-U.S. DPF Principles, the UK Extension and the Swiss-U.S. DPF Principles, unless we can prove that we are not responsible for the event giving rise to the damage.

Data Subject Rights

You have the right to access personal information we hold about you and to ask that your personal information be corrected or erased. If the processing is based on your consent or on a contract, and where such processing is carried out by automated means, you may also have the right to receive your personal information which you have provided to us and have the right to transmit it to another controller, where technically feasible (data portability). You may also have the right to object to processing of your personal information, which is based on our legitimate interest, as well as to processing for the purposes of direct marketing. In addition, you also have the right to request that we restrict certain processing. Where the processing is based on consent, you also have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal. If you would like to exercise any of these rights, please contact us at info@sugarsistersmiami.com.

Complaints

If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside, work or where the alleged infringement took place. For contact details of your data protection authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm, or for Swiss residents, see https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.

CONTACT US

If you have any questions about this Policy, please contact us at: info@sugarsistersmiami.com.

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