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LAST UPDATED: December 19, 2025

This Privacy Policy describes how Commerce Media Holdings, LLC, d/b/a Complex, together with its parents, partners and affiliates (collectively, “Complex,” “we”, “us” and “our”) collects, uses, and discloses your information when you visit websites (including mobile-optimized versions) and applications which have an authorized link to this Privacy Policy (each a “Site” and collectively, “Sites”), and otherwise interact with us online and offline.

United States users you can find out about your privacy rights \"Privacy Information for United States Residents\" section.

1. Who we are
2. About this Privacy Policy
3. Changes to this Privacy Policy
4. How to contact us
5. Data we collect and how
6. Aggregated data
7. How we collect data
8. Marketing Choices
9. Disclosing your data
10. UK and EU users: international transfer of your data
11. Retaining your data
12. Third-Party Sites
13. Cookie policy
14. Privacy information for EEA and UK users
15. Privacy Information for United States Residents
16. Notice for California Users
17. Complex Legal Entities

1. Who we are

When we mention “Complex”, “Commerce Media Holdings, LLC”, “we”, “us” or “our” in this Privacy Policy, we mean Commerce Media Holdings, LLC. COMMERCE MEDIA HOLDINGS, LLC legal entities are listed in our section 16.

2. About this Privacy Notice

This Privacy Policy explains how Complexcollects, uses, and discloses your data. We collect data when you use our website(s), mobile apps, and other online and offline products, services and experiences, and when you interact or make purchases at any of our retail locations (collectively, the “Services”). We may process your data when you: (i) purchase our Services or products on any of our Websites or at any of our retail locations; or (ii) act as a business partner such as vendor, supplier, distributor, retailer, or service provider.

By using the Services, you agree to and accept the terms of this Privacy Policy, which is part of the Terms and Conditions governing use of the Services. Complex may change or add to this Privacy Policy from time to time. When that happens, Complex will post the revised Privacy Policy here. Your use of the Services after changes to this Privacy Policy have been posted constitutes your knowledge and acceptance of those changes (in other words, that the changes may be applied to the information we collect from and about you). Please do not access or use the Services if you do not agree to the terms of this Privacy Policy.

This Privacy Policy does not apply to any third parties you may interact with through our Services. From time to time, we partner with third parties to provide you with products, promotions or other experiences. If those third parties will receive your personal data, we will make their privacy policy available to you where required by applicable law.

3. Changes to this Privacy Policy

We’re likely to update this Privacy Policy in the future and when we make changes, we will revise the date at the top of the policy. When we make material changes, we will notify you through the Services, such as on our homepage, or via email or other communication. Please come back and check this page from time to time for the latest information on our privacy practices.

4. How to contact us

If you have questions or concerns about the information in this Privacy Policy, our handling of your data more generally, your choices and rights regarding such use, or wish to exercise your rights under law, please do not hesitate to contact us at:

Commerce Media Holdings, LLC

7060 Hollywood Blvd, Floor 2

Los Angeles, CA 90028

Attn: Legal Department

data-privacy@complex.com

5. What data we collect and how

5.1 Data you provide to us.

We collect data you provide directly to us.

Payment data. To order products or services through our Services, you will need to provide us with payment information (like your bank account or credit card information). Please note that your financial information is collected and stored by our third party payment processing company. Use and storage of that data is governed by the third party payment processor’s applicable privacy policy.
Purchase data. If you make a purchase from a third party after clicking on an affiliate link through the Services, we will receive data about the purchase so that we can get credit for sending you to that third party. Transaction and Financial Information including your transactions (such as through the Complex Shop) and your payment method (valid credit card number, type, expiration date or other financial information), which is collected and stored by our third party payment processing company, Shopify Payments (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s terms of service and privacy policy. Complex Shop also accepts payment through PayPal (governed by its user agreement and privacy policy).
Other data you disclose through the Services to Complex. You may provide us with data when you fill in a form, conduct a search, respond to surveys, post to community forums, provide us with feedback, participate in promotions, use other features of the Services, provide other information to Complex, or use other features of the Services.

5.2 Data that we collect automatically about your browser and device.

When you access or use the Services, we use cookies and similar technologies that collect information about your browser and device:

Log Data. We automatically receive and record information from your device or web browser when you interact with the Services. For example, we collect your internet protocol (IP) address, mobile device ID, time zone setting, language preference, operating system, platform, internet service provider (ISP), and links you have clicked on or provided to others, including through email and social media.
Cookie Data. When you visit the Services, we will set certain “cookies” and similar tracking technologies on your device, including cookies and web beacons (“Cookies”). For more information about cookies and how to disable them, please see our “Cookie Policy” section below.

We and our ad and analytics partners also may use these technologies to collect data about your online activities over time and across third-party websites or other online services (behavioral tracking) to help us better understand users of the Services and provide advertising that we think will be of more interest to you.

5.3 Location data.

We use your IP address to infer your approximate location. We may also collect the language option or country you choose. When we provide certain services, such as providing you with a version of our Services that is localized to your country, we link location data to other information we have collected about you to provide you with a localized experience.

5.4 Special category data.

When we conduct research or carry out surveys and you participate in our research or surveys, we may collect sensitive data that you voluntarily provide, for example, information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life or sexual orientation. We will get your explicit consent for our collection, use, or disclosure of this data as required by law.

6. Aggregated data

6.1 We analyze and aggregate data we collect, such as the number and frequency of your visits to the Services, to produce anonymized metrics and statistical information that does not identify you as an individual. We are able to use and disclose such data for any purposes.
6.2 We combine information about you with information about other users to create audience segments of aggregated data, for example, statistical, demographic and usage data. If we combine or connect aggregated data with your data, we treat the combined data in accordance with this Privacy Policy.

7. How we collect data

7.1 From You. You may give us your data directly, fund us by donation, support us by paying for a subscription, buy products or services, subscribe to our newsletters, opt-in to marketing communications, publish posts or comments, enter a competition, participate in a promotion or survey, ask for user support, or contact us for any reason.\n
- We offer account sign-in with third party sign-in services, such as Google, to make it easier to create and access your account. When you use this option, we receive your name, email address, and profile picture from Google for authentication purposes only. We do not access or share any other Google account data through the Google sign-in feature.
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7.2 Using Cookies. We collect information about your devices and browsing actions and interests by using cookies and similar technologies. Our “Cookie Policy” section provides more details on how this works.
7.3 From our Advertising Partners. Third parties who provide advertising and related services (such as analytics providers and ad networks, our “Advertising Partners” may give us your data so that we can compare it to data we hold in order to determine if you are the same individual (this is sometimes called “cookie-matching”). We may collect data from unaffiliated third parties so we can better understand you and provide you with information and offers that may be of interest to you. For example, we may receive information about your interests or preferences as well as contact information, such as email address.
7.4 From our Advertisers and Affiliate Partners. We may receive your data from third parties when you buy things through our Services or when you buy things from a third party after clicking on an affiliate link in our content. This information may include your contact details and financial and transaction data (such as items purchased and purchase price) from providers of technical, payment and delivery services.
7.5 From Social Media Platforms. If you access our Services using your Facebook or Google credentials, we will automatically collect certain information, such as your Facebook or Google user ID. We will use any information collected from Facebook or Google, including the user ID Facebook or Google attributed to you, only in accordance with Facebook’s or Google’s policies and your preferences selected through Facebook or Google.

8. How we use your data:

We use the data we collect to provide, maintain, and improve our Services. We also use the data we collect to:

Send you technical notices, updates, security alerts and support and administrative messages and to respond to your comments, questions and customer service requests;
Communicate with you about products, services, offers, and events offered by Complex and others, and provide news and information we think will be of interest to you;
Make inferences about your interests and preferences (including at a household level). Your interests and preferences are inferred from data we collect about the content you have interacted with, how long you interacted with them, how often you interacted with them, and the nature of your interaction with the content;
Personalize and improve the Services and provide you with advertisements, content or features that match your profile, activities or interests;
Customize content that our third-party Advertising Partners deliver on the Services (such as personalized third-party advertising);
Creating and updating profiles and audience segments that can be used for analytics, interested-based advertising and marketing on the Services, and on websites, mobile apps and other platforms controller by our advertisers and other third party advertising partners (“Third Party Sites”);
We may use information about you, such as your email address, to identify you across the devices you use to access the Services, as well as offline. This helps us learn more about your interests and preferences, which we use for advertising on the Services and Third Party Sites;
Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
Monitor and analyze trends, usage and activities in connection with our Services and personalize and improve the Services;
Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Complex and others; and
Carry out any other purpose described to you at the time the data was collected.

9. Marketing choices

When you sign up for a promotion like a sweepstakes, or subscribe to our newsletters, we use your data to help us decide which products, services and offers may be of interest to you. We will send marketing messages to you if you have asked us to send you information, bought goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion. If you opt out of receiving marketing messages, we may still send you non-promotional emails, such as those about our ongoing business relations. We will ask for your consent before we disclose your personal data with any third party for direct marketing purposes.

You may unsubscribe from marketing messages through a link we include on messages we send you. You can also ask us to stop sending you marketing messages at any time by contacting us at: data-privacy@complex.com.

10 Disclosing your data

Complex may disclose data about you as follows or as otherwise described in this Privacy Policy:

Within Complex. We disclose your data within Complex’s legal entities where necessary to fulfill a contract or precontractual measures, or where we have a legitimate interest in doing so or a legal obligation to do so. Complex’s legal entities are listed in our “Complex Legal Entities” section;
With vendors, consultants, and other service providers who process your data on our behalf when they provide services to us, for example data analytics, research, marketing and financial services;
With third-party service providers to help us process and fulfil your purchases and use of our products and Services, for example:
We use Stripe to help us process payments through our Services—you can read more about how Stripe uses data here: https://stripe.com/privacy;
we use Shopify to power our online store--you can read more about how Shopify uses data here: https://www.shopify.com/legal/privacy;
we also use Violet to power our online store – you can read more about how Violet uses data here: https://violet.io/privacy-policy;
and we also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses data here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
With Brands, Labels, and content providers who’s events, artists, content creators, and contributors you follow, interact with, or make purchases related to though the Complex Services: this may include Universal Music Group and its affiliates—you can read more about how Universal Music Group uses your data here: https://privacy.umusic.com/.
With Advertising Partners to customize your experience and better tailor the services, products, marketing and advertising on our Services and on their Third Party Sites. Our Advertising Partners are companies that provide services that help us provide advertising to you. These companies may use their own tracking technologies to collect or request information about you. For more information, please see our “Cookie Policy” section.
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
We may be legally required to disclose your data without your consent in some circumstances, for example to comply with a court order or law enforcement. In such circumstances, we will only disclose your data if we have a good-faith belief that such disclosure is required under applicable legal obligations.

Please note that we will not sell or share your mobile phone number or your message consent preferences with third parties for their promotional or marketing purposes except where you explicitly consent to such disclosure.

Other Disclosures

We may also disclose aggregated or de-identified information, which cannot reasonably be used to identify you (we do not attempt to re-identify de-identified information, except as permitted or required by law). For example, we may disclose aggregated or de-identified information with our ad partners and service providers so that we, and they, can understand how people use our Services; this helps us grow our business and improve and develop our products and services.

We may also disclose information about you along with a hashed version of your email address with our Advertising Partners so that they and we can facilitate customized ad campaigns and other offers on the Services and on other platforms. “Hashing” transforms your email into an unrecognizable series of numbers and letters (e.g. a “hashed” version of jane@email.com would be k5f7g23@email.com).

11. Legal Bases for Processing Your Data

The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to use or disclose your “personal data” as such term is defined under applicable law. To the extent that those laws apply, our legal grounds are as follows:

To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our customers, or to take steps at customers’ requests in anticipation of entering into a contract with them. For example, we handle personal data on this basis to process and fulfill your orders.
Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as to fulfill customer service requests, market our services to you, protect our users, personnel and property, and analyze and improve the Services.
Legal compliance: We use and disclose personal data in certain ways to comply with our legal obligations.

12. International transfer of your personal data

12.1 When we process your data within Complex, we will do so in countries in which we have offices (United States).
12.2 Third parties with whom we disclose your data may be based outside the EEA or other international jurisdictions and their processing of your data may involve a transfer of data outside of those jurisdictions. For more information, please refer to the privacy policy links for such third parties in our consent management platform.
12.3 Where required, our agreements with those third parties include appropriate mechanisms to transfer your data, such as approved standard contractual clauses, and otherwise make clear the standards we expect of them in order to safeguard your information and your legal rights.

13. Retaining and securing your data

13.1 We generally keep your data for as long as we need it for the purposes for which it was collected. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. Please note, data may persist in copies made for backup and business continuity purposes for additional time.
13.2 When we decide how long we will keep your information we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, why we need it, and any relevant legal requirements (such as legal retention and destruction periods).
13.3 We may anonymize your data (so that it can no longer be associated with you) for research or statistical purposes.
13.4 We have implemented administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

13. Social Media Platforms and Other Third-Party Sites

13.1 Our sites and apps may include links to third-party sites, apps and social media platforms (“Third-Party Sites”). Clicking on those links may allow third parties to collect or disclose data about you. We do not endorse or control Third-Party Sites, each of which are governed by its own terms of service and privacy policy. We encourage you to read their privacy policies and terms so that you understand how they process information about you. We are not responsible for any damages or other harms that may arise when you leave Complex and interact with Third-Party Sites. Please take all protections necessary to protect yourself when accessing Third-Party Sites, particularly when downloading content or making purchases.
13.2 The Services may offer social features and other integrated tools, which let you publish actions you take on our Services with your friends or the public on social media platforms. We also use the analytics tools provided by the social media platforms to help us to understand how people interact with our social media presence, to identify trends and to carry out joint promotional activities with those platforms. For example, sometimes we agree with a social media platform that we will jointly promote certain content.
13.3 We receive aggregated statistical information from social media platforms about the performance of our posts and promoted content, such as numbers of views and kinds of viewers. This data is aggregated and anonymized by the social media platform before it is given to us.
13.4 We also use the paid advertising and paid content tools provided by the social media platforms to help us carry out advertising campaigns for our advertisers and to promote our content on the social media platforms. For example, we use the “Promoted Pins” tool on Pinterest to promote editorial or paid content to visitors to Pinterest. Again, we only receive aggregated statistical information from the social media platforms. This is information about interactions with our ads and paid content, such as number of views, number of times shared and so on.
13.5 We process information provided to us by the social media platforms on the basis of our legitimate interest in interacting with our audience on social media and using social media to promote our content.

For more information about the purpose and scope of data collection and processing in connection with social features or your use of the social media platforms, please visit the privacy policies of the respective entities at the following links:

Facebook and Instagram - https://en-gb.facebook.com/policy.php
Twitter - https://twitter.com/en/privacy
YouTube - https://policies.google.com/privacy?hl=en
Snapchat - https://www.snap.com/en-US/privacy/privacy-center/
Twitch - https://www.twitch.tv/p/legal/privacy-policy/
TikTok - https://www.tiktok.com/en/privacy-policy
Pinterest- https://policy.pinterest.com/en/privacy-policy
Tumblr - https://www.tumblr.com/privacy
LinkedIn - https://www.linkedin.com/legal/privacy-policy
LINE - https://terms.line.me/line_rules

14. Cookie policy

What Are Cookies?

Cookies are small data text files that are used to identify your computer or device online. When you visit a website, a cookie is created and stored on your hard drive so that that website can recognize you while you are on that website. Some cookies are “session-based,” which means they disappear once you leave the website. Others are “persistent,” which means they are stored on your device until you delete them and they allow a website to recognize you each time you visit the website. Cookies are just one technology used to collect information online. A “web beacon,” also known as a tag, pixel tag, or clear GIF, is also used to transmit information back to a web server. When you interact with our mobile apps we may use SDKs, which act like cookies, or we may use other identifiers to help us identify your device. When we talk about “Cookies” in this Privacy Policy, we mean not just cookies, but web beacons, SDKs and similar technologies.

What Types of Cookies are on the Services?

First Party Cookies. Our Services use our own cookies to recognize you and remember you as a unique user.
Session Cookies remember you during your session on our Services. They are deleted when you log out of the Services and when you close your web browser. We use session Cookies to ensure content is displayed correctly on the Services, to balance and monitor load on our servers, and for other technical matters essential to the operation of our Services. You can configure your device to reject these cookies, but our Services will probably not work correctly, or at all, if you do.
Consent cookies are used by our consent management platform we employ to record your preferences about third party cookies described below, and to store and disclose your preference with those third parties. These cookies are essential for compliance with the legal obligations imposed on us and on third parties with whom we have a business relationship to ensure we request your consent, record your consent preferences, and act on such consent preferences.
Analytics cookies. Analytics cookies are used by us and by third parties who process data for us for data analytics purposes (for example Google Analytics) so that we can manage and improve the performance and design of our Services and for monitoring, auditing, research and reporting. We have activated Google’s IP anonymization function on our Sites. This will cause your IP address to be cut by Google within Member States of the European Union or in other countries party to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Sites, to compile reports on Site activity and to provide us with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. With respect to Google Analytics, you can read about how Google uses data gathered for that purpose here.
Third party cookies: advertising and affiliate links. Our Advertising Partners and our affiliate links partners collect data from you for the purposes they disclose through our cookie consent management platform.
Advertising Partners include ad networks such as third party ad servers, ad agencies, ad technology vendors and research firms.** **
Affiliate links partners pay us when you buy things from them or another third party after clicking on an affiliate link in our content.
Our Advertising Partners use third party cookies to serve ads to you and to target you with tailored (or personalized) ads when you are using the Services and when you visit Third-Party Sites. They also use cookies to measure traffic on the Services (for example to track ad views).
We and our Advertising Partners may also use cookies to associate you with a phone number that you have previously provided. If you have opted in to receiving promotional text messages from us, we may send you advertisements and reminders about items that you have added to your shopping cart but have not purchased.
Advertising Partners and affiliate links partners may view, edit or set their own cookies on your mobile device or web browser when you interact with our Services. They use cookies to track your use of our Services and your activities elsewhere online. We provide links to their privacy policies in our consent management platform, which you can access by clicking here.

What Information do Cookies Collect?

Cookies and similar technologies allow us to collect the following types of data: a unique ID assigned to your device; IP address; device and browser type; operating system; referring URLs; content viewed or other actions taken through our Services; time and date of those actions; country and language selected.

What Choices Do you Have?

Browsers and devices have tools that allow you to disable Cookies. If you disable Cookies you may not be able to access all the features of our services. We suggest that you keep our essential cookies active for a better user experience and to help us keep improving and developing our products and services. You can decide who you will allow to set third party cookies on your browser or device by going to our consent preferences center or clicking the 'Cookies' link on the footer of our site. You can change your mind and revisit your consent choices at any time by returning there.

If you would like more information about this practice and to know your choices about having your information used in this manner by our partners, you may visit:

14. Privacy information for EEA and UK users

14.1 Information for UK/EU Users (including legal bases)

We will use your personal data only for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for another purpose, we will explain the legal basis we rely on.

For the legal bases on which we process your personal data, please see “Legal Bases for Processing Your Data” above.

14.2 Legal rights for EEA and UK users

If you are an EU or UK resident, you have certain rights in respect of the information that we hold about you. Below is a short overview of those rights:

Access. With some exceptions designed to protect the rights of others, you have the right to a copy of the personal data that we hold about you. Where the data is data that you have given to us, you have the right to receive your copy of it in a common electronic format, and to provide copies of it to other people if you wish.
Correction. You have the right to have the personal data we hold about you corrected if it is factually inaccurate. This right does not extend to matters of opinion, such as views expressed in editorial content.
Deletion. In some limited circumstances, you have the right to have personal data that we hold about you erased (the “right to be forgotten”). This right is not generally available where we still have a valid legal reason to keep the data (for example, because we are obliged to do so by law).
Objection. You have the right to object to our processing of your personal data where we rely on “legitimate interests” as our legal basis for processing, but we may be able to continue processing if our interest outweighs your objection.
Withdrawing consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop that processing unless we have another legal basis on which to continue.

14.3 How to exercise your rights

To exercise your rights, please complete the form on our Request Portal which can be accessed here. In order to protect your privacy and that of others, we will ask you to prove your identity before we take any steps in response to a request you have made. If a third party is making a request on your behalf, we will ask them to prove that they have your permission to act for you.

We may contact you to ask you for further information to help you exercise your legal rights or to speed up our response. We will try to respond to requests within one month and we will let you know if we need to take longer, for example because your request is complicated. We may have an overriding lawful basis for processing your personal data, or certain exemptions may apply. If we refuse your request, we will explain why. You may also reach us at data-privacy@complex.com.

14.4 Complaints

You have the right to complain about data privacy matters to the Information Commissioner’s Office (www.ico.org.uk), or the relevant data protection regulator in your country of residence. You can contact the ICO on 0303 123 1113. We invite you to raise your concerns with us first, so that we can try to resolve them.

15. Privacy Information for United States Residents

Residents of certain US states (including California, Colorado, Connecticut, Minnesota, Montana, Oregon, Tennessee, Texas, Utah and Virginia) and residents of the EU, UK, and other international jurisdictions have certain rights in relation to your personal information (as that term and similar terms, such as “personal data,” are defined in applicable law). For example, you have the right to request that we:

Confirm whether are process personal information about you;
Correct inaccurate personal information we have about you;
Provide access to and/or a copy of personal information we hold about you;
Delete personal information we have about you;
Opt out of the processing your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable
California and Oregon residents can also request information about the categories of personal information we collect, disclose or sell or share about you; California residents can request the sources of such information, the business or commercial purpose for collecting or selling or sharing your personal information; and the categories of third parties to whom we disclose personal information. Such information is also set forth in this Privacy Policy.
Oregon and Minnesota residents can request a list of the specific third parties, other than natural persons, to which we have disclosed personal information.
EU/UK residents can object to the processing of personal information and to opt out of processing for direct marketing purposes.

Residents of the US states noted above also have opt-out rights, discussed further below. If you are a California resident, please also see the section on “Notice for California Users” below for certain information specific to California residents.

If you are a resident of Virginia, Minnesota, Montana, Oregon, Tennessee, Texas, Colorado, or Connecticut, and we deny your personal information request, you have the right to appeal our denial. You can exercise this right by emailing us at data-privacy@complex.com with “Privacy Appeal” in the subject line or mailing us at Commerce Media Holdings, LLC, 7060 Hollywood Blvd, Floor 2, Los Angeles, CA 90028 Attn: Legal Department. Your description must include your full name and, if applicable, the email address used for your Account with us, along with a copy of the denial notice you received from us.

Please note: Your rights and our responses will vary based on your state or country if you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.

15.1 “Sharing” and “Selling” Personal Data

If you are a California, Colorado, Connecticut, Montana, Oregon, Texas, Utah or Virginia resident, you may opt out of certain processing of your personal information, including for targeted advertising, under applicable law.

We work with third-party partners to help us better advertise our Services and help us provide our Services for free and provide content that is more relevant to you on our Services and other third-party sites and apps. These partners collect personal information via cookies and similar technologies placed on our Services that allow them to deliver ads that are more relevant to you and analyze your interactions with those ads. These cookies may be considered to be a “sale” of personal information or “sharing” or “processing” of personal information for “targeted advertising” purposes under applicable law.

15.2 How to Exercise Your Rights

Opt-out of Sale/Share/Targeted Advertising.

If you would like to opt out of the sale or sharing of your personal data for targeted advertising, please visit this page:

Do Not Sell or Share My Personal Information (also linked in our Sites footer)

or contact us at data-privacy@complex.com.

Alternatively, if you have a legally-recognized browser-based opt-out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.

Please note that because these activities are based on Cookies, you will need to opt out again if you visit one of our Services from a different device or browser or if you clear your Cookies. Your selections are specific to the device, website, and browser you are using, and are deleted whenever you clear your browser’s cache. We do not knowingly sell or share the personal data of minors under 16 years of age without legally-required affirmative authorization.** **

To opt out of the offline disclosure of your information to third parties for these purposes, please email us at data-privacy@complex.com.

Exercising Your Other Privacy Rights

You can find instructions on how to proceed at our consent preferences center. You may exercise your rights, such as by completing the form on our Request Portal which can be accessed here. You may also reach us at data-privacy@complex.com.

Please note that the verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you, including when an authorized agent makes a request on your behalf. Making a verifiable consumer request does not require you to create an Account with us. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Only you or a person that you authorize to act on your behalf may make a verifiable consumer request related to your personal data. If you are an authorized agent submitting a request on behalf of another individual, we may require proof of your written authorization before processing the request. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or deletion twice within a 12-month period.

Please note that certain data may be exempt from such requests, such as access, data portability, correction, and deletion requests, under US Privacy Law. For example, we need to retain certain data in order to provide the Services to you or to comply with our legal obligations.

As described above, if we are unable to honor your request or you are not satisfied with the outcome of your request, you may have the right, within a reasonable period of time, to appeal our decision. Please send your appeal by email to data-privacy@complex.com with “Privacy Appeal” in the subject line.

16. Notice for California Users

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with information about:

the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and
the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information.

Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across distinct online services, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. We “share” information with our advertising partners to provide more relevant and tailored advertising to you regarding our Services. Moreover, our use of third-party analytics services and online advertising services may result in the sharing of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a “sale” under the CCPA.

In the past 12 months, we have processed the categories of personal information listed in the table below. The table also lists, for each category, the source, business purpose, and a general description of third parties to whom this information may be disclosed. For more details regarding the sources, business purposes, and third parties to which we disclose this information, please see Sections 5-9 of this Privacy Policy above.

Personal Information Category

Source of Information

Business Purpose of Use

Third Parties to Whom Information is Disclosed

Third Parties to Whom Information is Sold/Shared

Identifiers (e.g., name, mailing address, phone number, email address, username)

You and/or your use of the Services

Provide the Services
Personalize the Services
Respond to your requests for information
Provide you with relevant offers and promotions
Analyze and improve the Services
For security and legal purposes
Affiliates
Vendors
Entities for Legal Purposes
Advertising and Analytics Vendors/Partners

Staple & Hue

About Staple & Hue

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Staple & Hue