AP Holdings Group Inc. values our customers and respects your privacy. We collect information about you through our Site or in stores in an effort to improve your browsing experience and to communicate with you about our Services. This Privacy Policy applies to information collected by us (including any of our subsidiaries or corporate affiliates, collectively, “AP Holdings Group Inc.,” “we,” “us” or “our”) in connection with our Services both in-store and online. This Privacy Policy is incorporated into and forms part of the terms and conditions (“Terms”), and uses terminology already defined in the Terms.

This Privacy Policy applies to information collected through our Site, third party platforms related to our brand, social networking services, mobile applications, retail and in-store platforms, direct marketing campaigns, messaging services or other online communications, events, purchases and requests. As described in herein, we may share your information with our affiliated companies and, under certain circumstances, with third parties that provide services on our behalf, or with whom we have partnered to offer a particular product or service.

This Privacy Policy further describes the information that we collect about you, why we collect it, how we use it, and when we share your information with third parties. This Privacy Policy also describes the choices that you can make about how we collect and use your information. By using the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree, please do not use the Services. If we change this Privacy Policy in a material way, we will provide appropriate notice to you. You may exercise your choices about how we collect and use your information consistent with this policy at any time.

If you have any questions about this Privacy Policy, please contact us as described in the section entitled “Contact”, below.

Information Collected by AP Holdings Group Inc.

By contacting us, filling any contact form or using any of our Services, you consent to the use of your information, including, but not limited to, your personal data, in line with this Privacy Policy.

We may collect information from you relating to your identity, contact information, and personal interests, preferences and habits, including, but not limited to, your name, email address, postal address, phone number, credit card number, gender, birthday, lifestyle preferences, behavioral characteristics and other demographic information. We may also collect information from you about technical data relating to your use of our Services, including, but not limited to, your internet protocol (IP) address, your browsing data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, as well as other details about the devices that you use to access. Your information is collected when you visit our Site or use our Services, place an order online or by phone, make a purchase or return, save your information with us online, contact us with a question or concern, or participate in a contest, promotion, or survey, or interact with us in any other way. We maintain a record of your product interests and the purchases you make, which we may also combine with information acquired from other parties. Additionally, you may also be given the option to link to your social media accounts through our Services and, if you do, we may automatically receive certain information from you based on your privacy settings. We may also receive information about you from third parties, or with whom we have a business relationship.

You may also decide to provide us with another person’s information (such as name, email, address, or phone number) so that we may recommend or send products or services to such person, or so that we may facilitate your communication with other people. Local law may require you to seek the consent of your contacts to provide their personal information to us (or in connection with using our Services), and we may in turn use that information in accordance with the terms of this Privacy Policy. Where required by law, the consent from the person whose information you provided to us shall be required by you first.

Where we need to collect your information as required by law, or under the terms of a contract we have with you, and you fail to provide that information when requested by us, we may not be able to perform the contract that we have, or are desiring to enter into contact with you (for example, to provide you with products and services through our Services). In this case, we may have to cancel the contract that we have with you, and notify you accordingly.

Collection and Use of IP Addresses

Your IP address is a number that is automatically assigned to your computer by your Internet Service Provider (ISP). This number is logged automatically in our server log files whenever you visit our website, along with the time of your visit and the pages that you visited. It is also collected by pixel tags, as described above. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites.

We may use IP addresses for the same purposes for which we use your information, as well as for calculating website usage levels, helping diagnose server problems, and administering our website or your use of our website, including to provide opportunities to you and fulfill your requests and purchases. Except where otherwise required by law, we treat IP addresses, the server log files, and other related information as non-personal information.

Collecting and Using Non-Personal Information

Non-personal information includes information that does not identify you. It also includes aggregate information, for example, an analysis of the number of our customers who like a particular brand, based on personal information collected about several customers through our Site. AP Holdings Group Inc. may use non-personal information and share it with other third parties for any purpose. We may also combine non-personal information with personal information, such as combining your geographic location with your name, which shall be treated by us as personal information.

AP Holdings Group Inc.’s Use of My Information

We will only use your information when the law allows us to. Among other things, we may use your information in the following ways: (i) process and fulfill your order, including to send you emails to confirm your order status and shipment, and to process merchandise returns; (ii) to communicate with you and, with your consent when required, to send you information by email, postal mail, telephone, text message, or other means about our Services, unless you have directed us not to contact you with promotional communications; (iii) to permit you to create an online wish list and, if you choose, to share that list with your friends and others who are registered on the site and know your email address; (iv) to permit you to create a personal address book for your shipping address(es) on our site; (v) to administer and fulfill our contests and other promotions and programs in which you participate; (vi) to help us learn about your shopping preferences and purchasing history, including so that we may tailor offers to you; (vii) to help us address problems with and improve and develop our site design, products and services; (viii) to enhance your shopping experience; (is) for our internal business purposes, such as to analyze trends and statistics, for audits and to determine the effectiveness of our promotional campaigns; (x) to protect the security or integrity of our website and our business; (xi) to contact you if necessary regarding your transactions, your account, changes to our Terms and/or for other administrative purposes. Your information may also be used to provide more tailored marketing by phone, post, email, SMS or any other means (electronic or otherwise) and you expressly agree to such use. You always have the choice not to receive marketing information or calls by opting out.

We will retain your information for the period necessary to fulfill the purposes outlined in this policy unless a longer retention period is required or permitted by law.  Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the contract you have with us and notify you accordingly.

AP Holdings Group Inc.’s Share of My Information

We may share your information with our affiliated companies, for their use consistent with this Privacy Policy, including for marketing purposes. We may also share your information with our service providers who manage our customer information and perform services on our behalf, such as fulfilling promotions, sending communications to our customers, conducting surveys, processing credit cards, fulfilling your requests, or helping prevent, detect and investigate fraudulent or suspicious activities and transactions, as well as other purposes which may include financial reporting and analysis, strategic planning, the development of customer segmentation and metrics, research and analytics, and the development of new products and collaboration opportunities with designer brands.

In addition, we may share your information when we team up with another company to offer or provide products, services, contests, or promotions to our customers, and we may share information about you if necessary, in our good faith judgment, to: (1) comply with laws or regulations or in response to a valid subpoena, order, inquiry or request from government or public authorities in any country in which we operate, including the U.S. and Canada; (2) protect the rights, privacy or safety of AP Holdings Group Inc. or others; (3) protect against fraud or other illegal activity or for risk management purposes; (4) permit us to pursue available remedies or limit the damages we may sustain; or (5) enforce our policies or the terms and conditions applicable to any contest, promotion or program.

We may also transfer your personal data internally within us and other external third parties, which may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data to external third parties based outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal information to third countries.
• Where we use providers based in the US, we may transfer information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

In the unlikely event of a reorganization, sale, merger, joint venture, assignment, transfer or other disposition (including without limitation in connection with any bankruptcy or similar proceeding) of all or any portion of the business, assets or stock of AP Holdings Group Inc. or its parent company, our customers’ information and other information we have collected as described in this Privacy Policy may be among the transferred business assets and may be shared with other parties.

Changing My Information

You can review and change certain information related to your use of our Services (such as your name and contact information). To access your information, simply email us your requests.

You can also ask us to update your information by contacting us as described in the section entitled, “Contact”, below. Please note that any request to update your information may take up to 10 days for your email request and 6-8 weeks for your postal mail request.

Making Choices About Receiving Promotional Offers

We want to communicate with you only if you want to hear from us. If you prefer not to receive promotional information, such as information about special offers and sales events, from us, you can let us know by contacting our customer service as described in the section entitled, “Contact”.

Please be sure to include your full name and the email address you used when you registered with or made a purchase from us. If you ask us to remove your name and address from promotional lists, we will maintain your name in a “do not contact” file to ensure that we can honor your request. It may take up to 10 days to process your email request, and 6-8 weeks to process your postal mail request, during which period you may continue to receive communications from us.

If you change your mind, you can start receiving promotional communications by email from us again by re-signing up when you visit our Site, or by contacting customer service. Please note that when you make an online purchase from us, we will continue to confirm your order status and shipment by email. We may also need to contact you via telephone, email or postal mail with questions or information regarding your order.

 Protecting Kid’s Privacy

AP Holdings Group Inc. is concerned about the privacy and safety of children when they use the Internet. We will never knowingly request personally identifiable information online from anyone under the age of 13 without prior verifiable parental consent. Our Site is a general audience site and is not targeted to or intended for use by children.

Knowing if My Information Is Secure

We do our best to provide you with a safe and convenient shopping experience. We have in place certain physical, electronic, contractual, and managerial safeguards to protect the security and privacy of your information from unauthorized access, acquisition or disclosure. When you enter personal data on our website, we use Secure Sockets Layer (SSL) technology to protect your information as it is transmitted to us.

Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us sensitive information through email. If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem by contacting us as described in the section entitled, “Contact” below. If you choose to notify us by physical mail, this will delay the time it takes for us to respond to the problem.

“Phishing” is a scam designed to steal your information. If you receive an email that looks like it is from us asking you for your personal data, do not respond. We will never request your password, user name, credit card information or other personal data through email.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to request access to your personal data (commonly known as a “Data Subject Access Request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

You also have the right to ask us to correct, or to delete, remove, or erase your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure, which will be notified to you, if applicable, at the time of your request.

You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 Your California Privacy Rights

California Civil Code Section 1798.83 permits customers of AP Holdings Group Inc. who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please write to us at the following address:

AP Holdings Group Inc.

California Privacy Rights

AP Holdings Group Inc.

info@apannalisaperetti.com