annexbeach.com

Privacy policy

We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of

information we may collect from you or that you may provide (“Personal Information”) on the annexbeach.com website (“Website” or “Service”) and any of its

related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal

Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and this Website operator (“Operator”, “we”, “us” or “our”). If you are entering

into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case

the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must

not accept this agreement and may not access and use the Website and Services. By accessing and using the Website and Services, you acknowledge that

you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or

control, or to individuals that we do not employ or manage. This privacy policy was created with the help of the privacy policy generator.

Collection of information

Our top priority is customer data security and, as such, we exercise the no logs policy. We may process only minimal user data, only as much as it is

absolutely necessary to maintain the Website and Services. Information collected automatically is used only to identify potential cases of abuse and

establish statistical information regarding the usage and traGc of the Website and Services. This statistical information is not otherwise aggregated in such

a way that would identify any particular user of the system.

Privacy of children

We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal

Information through the Website and Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through

the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to

provide Personal Information through the Website and Services without their permission. We also ask that all parents and legal guardians overseeing the

care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their

permission.

Use and processing of collected information

We act as a data controller and a data processor when handling Personal Information, unless we have entered into a data processing agreement with you in

which case you would be the data controller and we would be the data processor.

Our role may also differ depending on the speciLc situation involving Personal Information. We act in the capacity of a data controller when we ask you to

submit your Personal Information that is necessary to ensure your access and use of the Website and Services. In such instances, we are a data controller

because we determine the purposes and means of the processing of Personal Information.

We act in the capacity of a data processor in situations when you submit Personal Information through the Website and Services. We do not own, control, or

make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such

instances, the User providing Personal Information acts as a data controller.

In order to make the Website and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you

do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect

from you may be used to help us run and operate the Website and Services.

Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the

following applies: (i) you have given your consent for one or more speciLc purposes; (ii) provision of information is necessary for the performance of an

agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are

subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of oGcial authority vested in us; (v) processing is

necessary for the purposes of the legitimate interests pursued by us or by a third party.

Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on

consent or any other of the legal bases. In any case, we will be happy to clarify the speciLc legal basis that applies to the processing, and in particular

whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Disclosure of information

Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information

with our aGliates, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Website and

Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We

will not share any personally identiLable information with third parties and will not share any information with unaGliated third parties.

Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal

requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use

or disclose any of the provided information for their own marketing or other purposes.

Retention of information

We will retain and use your Personal Information for the period necessary to comply with our legal obligations, to enforce our agreements, resolve disputes,

and unless a longer retention period is required or permitted by law up to a maximum of 1 months.

We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would

identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right

to rectiLcation, and the right to data portability cannot be enforced after the expiration of the retention period.

Cookies

Our Website and Services use “cookies” to help personalize your online experience. A cookie is a text Lle that is placed on your hard disk by a web page

server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web

server in the domain that issued the cookie to you. You may learn more about cookies and how they work in this guide.

We may use cookies to collect, store, and track information for security and personalization, and for statistical purposes. Please note that you have the

ability to accept or decline cookies. Most web browsers automatically accept cookies by default, but you can modify your browser settings to decline

cookies if you prefer.

Data analytics

Our Website and Services may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect

standard internet activity and usage information. The information gathered is used to compile statistical reports on User activity such as how often Users

visit our Website and Services, what pages they visit and for how long, etc. We use the information obtained from these analytics tools to monitor the

performance and improve our Website and Services. We do not use third-party analytics tools to track or to collect any personally identiLable information of

our Users and we will not associate any information gathered from the statistical reports with any individual User.

Do Not Track signals

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not

the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identiLable information

from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not

Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your

browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information.

Email marketing

We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address conLdential and will

not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a thirdparty

provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.

In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the

sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by

contacting us.

Links to other resources

The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy

practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy

statements of each and every resource that may collect Personal Information.

Information security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We

maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modiLcation, and disclosure

of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.

Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are

beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot

be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

Data breach

In the event we become aware that the security of the Website and Services has been compromised or Users’ Personal Information has been disclosed to

unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably

appropriate measures, including, but not limited to, investigation and reporting, as well as notiLcation to and cooperation with law enforcement authorities. In

the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a

result of the breach or if notice is otherwise required by law. When we do, we will send you an email.

Changes and amendments

We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the

updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have

provided.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise speciLed. Your continued use of the

Website and Services after the effective date of the revised Policy (or such other act speciLed at that time) will constitute your consent to those changes.

However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal

Information was collected.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting

your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the

Website and Services.

Contacting us

If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we

encourage you to contact us using the details below:

info@annexbeach.com

We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in

any event, within the timescales provided by applicable data protection laws.

This document was last updated on August 5, 2021