PRIVACY POLICY

1. Introduction

This Privacy Policy ("Policy") describes how BENM INC, a Washington corporation with its registered address at 100 N HOWARD ST STE R, SPOKANE, WA 99201-0508, UNITED STATES ("we", "us", "our", "Company"), collects, uses, discloses and protects personal information when you visit https://modelones.com (the "Site") and use our related services, sales, marketing and events (together, the "Services"). We take your privacy very seriously, and we appreciate that you are trusting us with your personal information. We encourage you to read this Policy carefully. If there are any terms in this Policy that you do not agree with, please discontinue use of our Services immediately. This Policy applies to all information collected through our Services. It may be updated from time to time to reflect changes in our practices or in applicable law; please check this page regularly for any changes. Our Site is not directed to children under thirteen (13) years of age, and we do not knowingly collect personal information from children under 13. See Section 16 (Children’s Privacy) for more information. All use of our Site is subject to our Terms of Use, which are incorporated into this Policy by reference.

2. Information We Collect

We collect the following categories of personal information about you, which are also mapped to the categories recognized under the California Consumer Privacy Act (CCPA):

2.1 Contact Information and Personal Identifiers

Such as your name, postal and billing address, email address, telephone number, username or social media handle. (CCPA category: Identifiers.)

2.2 Device and Online Identifiers

Such as IP address, device identifiers, browser type, website address and other online identifiers collected automatically when you visit our Site. (CCPA category: Internet or other electronic network activity information.)

2.3 Commercial Information

Such as the products or services you have purchased, returned or considered, your product preferences and your purchase history. (CCPA category: Commercial information.)

2.4 Payment Information

Such as payment card number, expiration date, delivery address and billing address. Payment card data is processed by our third-party payment processors and is not stored by us. (CCPA category: Categories of personal information described in Cal. Civ. Code § 1798.80(e).)

2.5 Geolocation Information

Such as your approximate location derived from your IP address or device settings. (CCPA category: Geolocation data.)

2.6 User Content

Such as photographs, videos, reviews, articles, survey responses and comments that you submit to us or post on our Site. (CCPA category: Audio, electronic, visual, thermal, olfactory or similar information; may include characteristics of protected classifications when you choose to share them.)

3. Sources of Information

We collect personal information from the following sources:
(a) Information you provide to us, such as when you create an account, place an order, contact us by email, telephone or other means, participate in a contest, survey or promotion, or join our loyalty program;
(b) Information collected automatically when you visit the Site, such as device data, usage data and cookie data (see Section 6);
(c) Information from third parties, including payment processors, shipping carriers, social media platforms, and advertising and analytics providers with whom you interact, to the extent permitted by law.

4. How We Use Your Information

We use the personal information we collect for the following business and commercial purposes:
(a) To provide products and services to you, such as fulfilling orders, processing payments, creating, servicing and maintaining your account and loyalty program membership, assisting with product selection and replenishment, and managing current or past purchases;
(b) To communicate with you, including to respond to your inquiries or complaints and to help you place an order;
(c) To administer your participation in special events, contests, sweepstakes, surveys, promotions and our loyalty program;
(d) For marketing and advertising, such as sending you marketing and advertising materials by email, text message or postal mail, and showing you advertisements for products and services tailored to your interests on social media and other websites;
(e) For analytics, such as understanding how you use our Site, determining what browsers and devices you use, and evaluating and improving our products, services, advertisements, Site and applications;
(f) To operate and improve our business, including quality assurance, research and development, and accounting, auditing and other internal business functions; 
(g) For legal and security purposes, such as detecting, preventing and prosecuting harmful, fraudulent or illegal activity, loss prevention, identifying and repairing bugs, and complying with applicable legal requirements, industry standards and our policies.
We will not sell your personal information to third parties. Your personal information or images shall not be used for advertising without your consent, except as described in this Policy.

5. Disclosure to Third Parties

We disclose personal information to the following categories of recipients for the purposes described in Section 4:
(a) Payment processors, to process your payments;
(b) Shipping and logistics carriers, to deliver your orders;
(c) Email and marketing service providers, to send promotional communications and manage our loyalty program;
(d) SMS and messaging partners, solely for the purpose of enabling and operating our text messaging program;
(e) Analytics and advertising providers, such as web analytics and social media advertising platforms;
(f) Professional advisors, including accountants, auditors, consultants and lawyers, subject to obligations of confidentiality;
(g) Legal and regulatory authorities, law enforcement agencies or courts, when required by law or for the establishment, exercise or defense of legal claims;
(h) A purchaser or successor in the event of a merger, acquisition, reorganization, dissolution or other transfer of all or part of our business or assets.
Where we engage third-party service providers to process personal information on our behalf, they are subject to contractual obligations to process the information only in accordance with our instructions and to implement measures to protect its confidentiality and security. We do not sell personal information to third parties, and we do not sell the personal information of minors under sixteen (16) years of age.

6.Cookies

(a) A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
(b) We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
(c) Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

7. Advertising and Your Choices

We may work with advertising partners who use cookies and similar technologies to serve ads to you on other websites and platforms, including social media. You can limit the use of your information for interest-based advertising through the following tools:
(a) Digital Advertising Alliance (DAA) AdChoices: optout.aboutads.info;
(b) Network Advertising Initiative (NAI): optout.networkadvertising.org; 
(c) Google Analytics opt-out: tools.google.com/dlpage/gaoptout.
You can also adjust advertising preferences within the privacy settings of the social media platforms you use.

8. Do Not Track

Some browsers can be configured to send "Do Not Track" (DNT) signals to websites. At this time, our Site does not respond to DNT signals. We support the Global Privacy Control (GPC) signal to the extent it is implemented on our Site, as described in Section 15.

9. SMS and Text Messaging

We value your privacy and the information you consent to share in relation to our SMS marketing service. We use this information to send you text notifications (including order updates and abandoned checkout reminders), text marketing offers, and transactional texts, including requests for reviews. Opt-in data and consent for text messaging will not be shared with any third parties except for messaging partners, for the purpose of enabling and operating our text messaging program.
Our Site uses cookies to keep track of items you put into your shopping cart, including when you have abandoned your checkout. This information is used to determine when to send cart reminder messages via SMS. To opt out of SMS messages, reply STOP to any message you receive; for help, reply HELP. Message frequency varies and message and data rates may apply, as described in our Terms of Use.

10. Data Security

We have implemented appropriate technical and organizational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure and unauthorized access, in accordance with applicable law. These measures include encryption of data in transit, access controls, and restrictions on access to personal information to personnel who need it to perform their job functions.
Because the internet is an open system, the transmission of information via the internet is not completely secure. While we take reasonable measures to protect your personal information, we cannot guarantee the security of data transmitted to us over the internet; any such transmission is at your own risk.

11. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, subject to applicable legal and tax obligations, as follows:
(a) Order and transaction records: retained for the period required by tax and accounting law, and thereafter deleted or anonymized;
(b) Account information: retained while your account is active and for a reasonable period thereafter;
(c) Marketing information: retained until you unsubscribe or withdraw your consent;
(d) Comments and their metadata: retained indefinitely, to allow us to recognize and approve follow-up comments; 
(e) Information subject to a legal claim or obligation: retained for the duration of the applicable limitation period and any required additional period.
When the applicable retention period has ended, we will either permanently delete or destroy the relevant personal information or anonymize it.

12. Your Privacy Rights

Subject to applicable law, you may have the following rights regarding your personal information:
(a) The right to request access to, or a copy of, the personal information we hold about you;
(b) The right to request correction of inaccurate or incomplete personal information;
(c) The right to request deletion of personal information we hold about you, subject to legal and administrative exceptions;
(d) The right to receive an exported file of the personal data we hold about you in a structured, commonly used and machine-readable format;
(e) The right to withdraw consent where processing is based on your consent; and
(f) The right to opt out of marketing communications at any time, including by clicking the unsubscribe link in any promotional email.
To exercise any of these rights, please contact us at the details in Section 21. To protect your privacy, we may need to verify your identity before responding. We will respond to verifiable requests within the period required by applicable law (generally within forty-five (45) days). We will not discriminate against you for exercising any of your privacy rights.

13. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, "CCPA/CPRA"), provides you with the following rights regarding the personal information we have collected in the preceding twelve (12) months:

13.1 Right to Know

You have the right to request that we disclose: (a) the categories of personal information we collected about you; (b) the categories of sources from which it was collected; (c) the business or commercial purposes for collecting or sharing it; (d) the categories of third parties to whom we disclosed it; and (e) the specific pieces of personal information we collected about you.

13.2 Right to Delete

You have the right to request that we delete personal information we have collected from you, subject to exceptions under the CCPA/CPRA, including where the information is necessary to complete a transaction, detect security incidents or fraud, debug the Site, comply with legal obligations, or make other internal and lawful uses compatible with the context in which you provided it.

13.3 Right to Correct

You have the right to request correction of inaccurate personal information that we maintain about you.

13.4 Right to Opt Out of Sale and Sharing

You have the right to opt out of the "sale" of your personal information and of the "sharing" of your personal information for cross-context behavioral advertising. We do not sell personal information, and we do not sell or share the personal information of minors under sixteen (16) years of age. If we engage in sharing for cross-context behavioral advertising, you may opt out as described in Section 15.

13.5 Right to Limit Use of Sensitive Personal Information

You have the right to limit our use and disclosure of sensitive personal information to purposes authorized by the CCPA/CPRA. We do not use sensitive personal information for purposes other than those authorized.

13.6 Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of your rights under the CCPA/CPRA, including denial of goods or services, different prices or rates, or different levels of quality.

13.7 How to Exercise Your California Rights

You or your authorized agent may submit a verifiable request by emailing support@modelones.com. We may take steps to verify your identity by comparing the information you provide with the information we have on file. We will respond to verifiable consumer requests within forty-five (45) days (and may extend by up to an additional forty-five (45) days where reasonably necessary). If you use an authorized agent, we may require proof that the agent is authorized to act on your behalf.

13.8 California "Shine the Light"

Under California Civil Code Section 1798.83 (the "Shine the Light" law), California residents may request a notice describing the categories of personal information we share with third parties for their direct marketing purposes, and the names and addresses of those third parties. To request such a notice, please contact us at support@modelones.com.

13.9 Notice of Financial Incentive

We may offer financial incentives, such as loyalty points and discounts through our Rewards program, in exchange for the collection of personal information. See Section 14 for details.

14. Financial Incentives and Our Rewards Program

We operate a Rewards and loyalty program through which you may earn points, discounts or other benefits in exchange for providing certain personal information, such as your email address, telephone number and purchase history, or for taking actions such as creating an account, joining our mailing list or referring friends.
The material terms of this incentive, including how points are earned and redeemed, are set out in the Rewards Program rules. Participation is voluntary, and the value of the incentive is reasonably related to the value of the personal information provided.
You may choose not to participate in the Rewards program without losing access to the core features of our Site, and you may opt out or cancel at any time. We do not offer incentives that deny you goods or services, or that charge different prices or provide different quality, as a penalty for exercising your privacy rights, except to the extent permitted by the CCPA/CPRA.

15. Do Not Sell or Share My Personal Information

We do not sell your personal information, as "sell" is defined under the CCPA/CPRA. However, we may "share" personal information (such as online identifiers and browsing activity) with advertising and social media partners for cross-context behavioral advertising, as described in Sections 6 and 7.
If you wish to opt out of the sale or sharing of your personal information, you may: Email us at support@modelones.com with the subject line "Do Not Sell or Share My Personal Information".
We do not sell or share the personal information of minors under sixteen (16) years of age, and we do not knowingly collect personal information from children under thirteen (13) years of age.

16. Children’s Privacy

Our Site is a general audience website and is not directed to children under thirteen (13) years of age. We do not knowingly collect personal information from children under 13 in compliance with the Children’s Online Privacy Protection Act (COPPA). If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@modelones.com, and we will take steps to delete such information from our records.

17. Third-Party Links

Our Site may contain links to other websites of interest. Once you use these links to leave our Site, we do not have any control over that other website. We are not responsible for the protection and privacy of any information you provide while visiting such sites, and such sites are not governed by this Policy. You should exercise caution and review the privacy statement applicable to the website in question.

18. International Data Transfers

Because our business operates internationally, personal information may be transferred to and processed in the United States and in other countries where our service providers are located, which may have data protection laws different from those in your country of residence. Where we transfer personal information from the European Economic Area (EEA), the United Kingdom or Switzerland to countries that do not provide an adequate level of protection, we rely on appropriate safeguards, including Standard Contractual Clauses, as applicable. You may request a copy of the relevant safeguards by contacting us at support@modelones.com.

19. Changes to This Privacy Policy

We may update this Policy periodically to reflect changes in our personal information practices or in applicable law. When we make material changes, we will update the "Last Updated" date at the top of this Policy and, where required by law, provide you with a more prominent notice, such as a notice on our Site or an email to you. Your continued use of our Services after the effective date of any changes constitutes acceptance of the revised Policy.

20. Contact Us

If you have any questions or concerns about this Policy or our privacy practices, please contact us:
BENM INC
100 N HOWARD ST STE R, SPOKANE, WA 99201-0508, UNITED STATES
Email: support@modelones.com

21. Definitions

21.1 Personal Information

Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, as defined under the CCPA/CPRA.

21.2 Sell

Selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating personal information to a third party for monetary or other valuable consideration, as defined under the CCPA/CPRA.

21.3 Share

Sharing, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating personal information to a third party for cross-context behavioral advertising, as defined under the CCPA/CPRA.

21.4 Service Provider and Processor

A third party that processes personal information on behalf of the Company under written contract and subject to confidentiality and security obligations.

21.5 Global Privacy Control (GPC)

A technical standard and browser signal that communicates your preference to opt out of the sale and sharing of your personal information to websites you visit.