Privacy Policy | Nomos Cigars

An overview of the nomoscigars.com Privacy Policy is below. This Privacy Policy applies to your use of any online services (e.g., website or mobile app) that posts a link to this Privacy Policy, regardless of how you access or use it.

It is important that you read and understand the entire Privacy Policy before using the Service.

NOMOSCIGARS.COM PRIVACY POLICY Thank you for visiting nomoscigars.com, an online service (e.g., website or mobile app), that posts a link to this Privacy Policy ( “Service” ) that is owned and operated by CTJM, LLC (referred to herein as “Company”, “We” or “Our”). This Privacy Policy will provide you with information as to how Company collects, uses, and shares information about you, including the choices Company offers with respect to that information, and applies to your use of any Service, regardless of how you access or use it. It does not apply to Company’s data collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection). For certain Services, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you.

By visiting or otherwise using the Service, you agree to the Service’s Terms of Use and consent to Company’s data collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service. If you do not agree and consent, please discontinue use of the Service, and uninstall Service downloads and applications, as applicable.

1. INFORMATION WE COLLECT. A. INFORMATION ABOUT YOU THAT YOU PROVIDE. Company, and/or its Service Providers (defined below), may collect information you provide directly to Company and/or its Service Providers via the Service. For example, Company collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties.

Information that Company, its Service Providers and/or Third-Party Services may collect may include: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number ( “Personal Information” ); and (2) demographic information, such as your gender, age, zip code, interests, and recent and upcoming purchases (“ Demographic Information ”). Except to the extent required by applicable law, Demographic Information is “non-Personal Information” (i.e., data that is not Personal Information under this Privacy Policy). In addition, Personal Information, including, without limitation, Company-Collected PI (defined below), once “de-identified” (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements) is also nonPersonal Information and may be used and shared without obligation to you, except as prohibited by applicable law. To the extent any non-Personal Information is combined by or on behalf of Company with Personal Information Company itself collects directly from you on the Service ( “Company-Collected PI” ), Company will treat the combined data as CompanyCollected PI under this Privacy Policy.

B. INFORMATION COLLECTED AUTOMATICALLY. Company, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service ( “Usage Information” ). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Company with Company-Collected PI, Company does not consider Usage Information (including, without limitation, unique device identifiers) to be Personal Information or Company-Collected PI.

THE METHODS THAT MAY BE USED ON THE SERVICE TO COLLECT USAGE INFORMATION INCLUDE: · Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files. · Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed ( “Tracking Technologies” ) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior. Here is more detail of types of Tracking Technologies:

• COOKIES A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service, and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features and functionalities of the Service may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manag er.html. The Service may associate some or all of these types of cookies with your devices.

• WEB BEACONS (“TRACKING PIXELS”) Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.

• EMBEDDED SCRIPTS An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from Company’s web server, or from a third-party with which Company works, and is active only while you are connected to the Service, and deleted or deactivated thereafter.

• LOCATION-IDENTIFYING TECHNOLOGIES GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked.

• FINGERPRINTING Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes of identification and/or tracking.

• DEVICE RECOGNITION TECHNOLOGIES Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) ( “Cross-device Data” ).

• IN-APP TRACKING METHODS There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps and/or devices. Some information about your use of the Service and certain Third-Party Services may be collected using Tracking Technologies across time and services, and used by Company and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third-Party Services. See Section 10 regarding certain choices regarding these activities.

Company is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 10 so that your consent to encountering them is meaningfully informed. C. Information Company Collects From Other Sources.

Company may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with Company-Collected PI. Notwithstanding anything to the contrary, except to the extent such data combined by or on behalf of Company with Company-Collected PI, this Privacy Policy is not intended to limit Company’s activities regarding such third-party-sourced, or non-Service-sourced, information (including Personal Information), and such data will only be treated as Company-Collected PI to the extend it is combined with Company-Collected PI. Company is not responsible or liable for the accuracy of the information provided by third parties or for third-party policies or practices.

2. HOW WE USE THE INFORMATION WE OBTAIN. Company may use information about you, including Company-Collected PI and other Personal Information, for any purposes not inconsistent with Company’s statements under this Privacy Policy, or otherwise made at the point of collection, and not prohibited by applicable law, including, without limitation, the following: · Allow you to participate in the features we offer on the Service; · Facilitate, manage, personalize, and improve your online experience; · Process your registration, manage your account and/or upload your User Generated Content (“ UGC ”).For more on the public nature of UGC, see Section 5 ; · Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices; · Company’s and Affiliates’ marketing and other purposes; · Improve the Service and for any other internal business purposes; · Tailor our content, advertisements, and offers; · Fulfill other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted or are required to do so; · Determine your location and manage digital content rights (e.g., territory restrictions); · Prevent and address fraud, breach of policies or terms, and threats or harm; and · To comply with legal process such as a search warrant, subpoena or court order, or if requested by regulatory agencies with authority over the tobacco industry such as the Food and Drug Administration.

3. INFORMATION WE SHARE WITH THIRD PARTIES. Company may share non-Personal Information, and Personal Information that is not deemed Company-Collected PI hereunder (provided that Company is aware of no restrictions of Company’s use, if any), with third parties, or Company and their affiliates ( “Affiliates” ) for any purpose. Company’s sharing of Company-Collected PI is, however, subject to the following: · Marketing: Subject to your communications choices explained in Section 10.C , and the rights of California residents, we may use your Personal Information to send you marketing communications. Absent your consent (which may be by means of opt-in, or a third-party interaction described in the next bullet point), however, Company will not share your Company-Collected PI with third parties, other than Affiliates, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below).

· Your Disclosure or Consent: As more fully described in Section 5 (Information You Disclose Publicly or to Others) and Section 6 (Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics), your activities on the Service may, by their nature, result in the sharing of your Company-Collected Personal Information (as well as your other Personal Information and your non-Personal Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such thirdparty data receipt and collection is subject to the privacy and business practices of that thirdparty, not Company.

Company may also share any information about you (including, without limitation, CompanyCollected PI) for any purposes not inconsistent with this Privacy Policy, or otherwise not prohibited by applicable law, including, without limitation: · Company’s agents, vendors, consultants, and other service providers (collectively “ Service Providers ”) may receive, or be given access to your information, including, without limitation, Personal Information, Demographic Information, and Usage Information, in connection with their work on Company’s behalf, provided however, Company does not authorize its Service Providers to use Company-Collected PI provided by Company to the Service Providers to send you direct marketing messages other than related to Company and Company Affiliates absent your consent.

· To comply with the law, law enforcement or other legal process, and in response to a government request (including, without limitation, Food and Drug Administration and other regulatory agency inquiries and requests); and · If Company believes your actions are inconsistent with Company’s terms of use, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of Company, the Service or its users, or any third-party. In addition, Company may share your Company-Collected PI (as well as your other Personal Information and your non-Personal Information), in connection with or during negotiations of any proposed or actual merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Company assets, or transfer of all or a portion of Company’s business to another company ( “Corporate Transactions” ).

4. SWEEPSTAKES, CONTESTS, AND PROMOTIONS. Company may offer sweepstakes, contests, and other promotions (each, a “Promotion” ), including Promotions jointly sponsored or offered by third parties, which may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your information, including Personal Information, may be disclosed to Company, Company Affiliates, co-sponsors, Service Providers, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Privacy Policy. Please review those rules carefully.

5. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS. The Service may permit you to post or submit UGC including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personal Information. If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including Company. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personal Information included in UGC is not subject to Company’s usage or sharing limitations, or other obligations, regarding Company-Collected PI or other Personal Information under this Privacy Policy or otherwise, and may be used and shared by Company and third parties to the fullest extent not prohibited by applicable law. Company encourages you to exercise caution when making decisions about what you disclose in such public areas. Although it is required to be twenty-one (21) years of age or older to use the Service, California minors who have improperly accessed the Service should see Section 11 regarding potential removal of certain UGC they have posted on the Service.

Additionally, the Service may offer you the option to send a communication to a friend. If so, Company relies on you to only send to people who are at least twenty-one (21) years of age and who have given you permission to do so. The friend’s Personal Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Company for any other marketing purpose unless Company obtains consent from that person. Your contact information and message may be included in the communication.

6. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS. The Service may include hyperlinks to, or include on or in connection with, the Service (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties ( “Third-Party Service(s)” ). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Information from you.

Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third-party social networks ( “Social Features” ). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Company’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5 ) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Service (e.g., by using a hashtag associated with Company or other Company Affiliates in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Company and Company Affiliates. Also, both Company and the third-party may have access to certain information about you and your use of the Service and any Third-Party Service.

Company may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on third-party services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising” ( “Interest-based Advertising” ), which may include sending you an ad on a third-party service after you have left the Service (i.e., “retargeting”).

Company may use Google Analytics, Adobe Analytics or other Service Providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help Company analyze Service users and how they use the Service. Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service’s activity, and providing other services relating to Service activity and other Internet usage.

Except to the extent we combine information we receive from Service Providers, Third-Party Services, or other third parties with Company-Collected PI, in which case Company will treat the combined information as Company-Collected PI under this Privacy Policy (see Section 1(c) ), data obtained by Company from a third-party, even in association with the Service, is not subject to Company’s limitations regarding Company-Collected PI under this Privacy Policy, however such data remains subject to any restrictions imposed on Company by the third-party, if any. Otherwise, the information collected, stored, and shared by third parties remains subject to their privacy policies and practices, including whether they continue to share information with Company, the types of information shared, and your choices on what is visible to others on Third-Party Services.

Company is not responsible for and makes no representations regarding the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Service, and encourages you to familiarize yourself with and consult their privacy policies and terms of use. See Section 10 for more on certain choices offered by some third parties regarding their data collection and use, including regarding Interest-based Advertising and analytics.

7. DATA SECURITY AND MONITORING. Company takes reasonable measures to protect Company-Collected PI (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and online digital storage are not completely secure and Company cannot guarantee the security of your information collected through the Service.

To help protect you and others, Company and its Service Providers may (but make no commitment to) monitor use of the Service, and may collect and use related information including Company-Collected PI and other Personal Information for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of and investigate and/or seek prosecution for any potential threats to or misuse of the Service; ensure compliance with the Terms of Use and this Privacy Policy; investigate violations of or enforce these agreements; and otherwise to protect the rights and property of Company, Company Affiliates, third parties, and other users. Monitoring may result in the collection, recording, and analysis of online activity or communications through our Service. If you do not consent to these conditions, you must discontinue your use of the Service.

8. INTERNATIONAL TRANSFER . Company is based in the U.S. and the information Company and its Service Providers collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Policy.

9. ACCESSING AND CHANGING INFORMATION. Company may provide web pages or other mechanisms allowing you to delete, correct, or update some of the Company-Collected PI, and potentially certain other information about you (e.g., account information). For instance, you can make changes to your account information by updating or modifying your online account information via the “My Account” link provided at the top of each page. Company will make good faith efforts to make requested changes in Company’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from Company’s databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.

10. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS. A. TRACKING TECHNOLOGIES GENERALLY. Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flashplayer/kb/disable-third-party-local-shared.html . Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

Some app-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Company currently does not alter Company’s practices when Company receives a “Do Not Track” signal from a visitor’s browser. Some third parties, however, may offer you choices regarding their Tracking Technologies. Company is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third-party analytics and advertising providers, see the next section. B. Analytics and Advertising Tracking Technologies.

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s ( “DAA” ) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices/ , and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative ( “NAI” ). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/ . Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use of a different device or web browsers or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Company supports the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising ( http://www.iab.net/media/file/ven-principles-07-01-09.pdf ) and expects that ad networks Company directly engages to serve you Interest-based Advertising will do so as well, though Company cannot guaranty their compliance. Company is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

C. COMMUNICATIONS. You can opt out of receiving certain promotional communications from Company at any time for promotional e-mails by following the instructions provided in e-mails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account. Please note that your opt-out is limited to the e-mail address used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, Company may, subject to applicable law, continue to send you nonpromotional communications, such as those about your account, transactions, servicing, or Company’s ongoing business relations.

11. YOUR CALIFORNIA PRIVACY RIGHTS. Your California Privacy Rights This PRIVACY NOTICE supplements the information contained in the above Privacy Policy and applies solely to California residents who have business relationships with us (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the California “Shine the Light” law, and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. Under California’s “Shine the Light” law, if you are a California resident who provides personal information in obtaining products or services for personal use, you may choose to opt out of any sharing of that personal information with third parties by one of our brands or affiliates with whom you have provided that personal information. If you are a California resident and (1) you wish to opt out; or (2) you wish to request information concerning whether one of our brands or affiliates has disclosed any of your personal information to any third parties for direct marketing purposes, you may contact us as specified in the “Contact For More Information” section below.

INFORMATION WE COLLECT We collect and retain the following categories of personal information from consumers, which we collect for the business purpose of complying with federal, state and local laws, and regulations governing our business, and to help us determine what products and services might be of greatest interest to you. Nomoscigars.com collects at least one item from each of the below categories of personal information identified in the California Consumer Privacy Act.

Category / Examples: A. Identifiers. Your real name, alias, date of birth, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, or other similar identifiers. B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, driver’s license or state identification card number, bank account number, or other financial information. Some personal information included in this category may overlap with other categories. C. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. D. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. E. Geolocation data. Physical location or movements. F. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We obtain the categories of personal information listed above from the following categories of sources: • Directly from our customers or their agents. For example, from documents that our customers provide to us related to the products or services for which they engage us.

• Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing products or services to them.

• Directly and indirectly from activity on the nomoscigars sites. For example, from submissions through our website portal or website usage details collected automatically.

• From third parties that interact with us in connection with the services we or they perform.

Sharing Personal Information We may disclose your personal information to our corporate affiliates and to third parties with whom we have joint marketing agreements for the purpose of offering complementary products and services. When we disclose personal information to our affiliates, service providers, and/or third parties, we do so under a contract that describes the business purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except for performing the services provided under the contract. We may have disclosed or sold the following categories of personal information: Category A: Identifiers Category B: California Customer Records personal information categories Category C: Commercial Information Category D: Internet or other similar network activity Category E: Geolocation data Category F: Inferences drawn from other personal information Access to or Requesting Deletion of Personal Information If you are a California resident, upon our receipt of a verifiable request from you, you can obtain access to the personal information about you which we have in our files, or which we have used or shared with third parties. This section describes your CCPA rights and explains how to exercise those rights. Requests to Know You have the right to request that we disclose certain information to you about our collection and use of your personal information, including: the categories and specific pieces of personal information we have collected about you. Requests to Delete You have the right to request that we delete any of your personal information that we have collected and retained, subject to certain exceptions in the CCPA. Once we receive and confirm your verifiable consumer request, we will delete your requested personal information from our records, unless an exception applies, and we will direct our service providers to similarly delete your personal information from their records. Exercising Your Request to Know and Request to Delete Rights In order to submit a verifiable consumer request to know what personal information we may have collected or shared, or to request the deletion of any of your personal information, you may contact us online at: info@nomoscigars.com. Upon receipt of a request by one of the above methods concerning your personal information, we will attempt to verify your identity (or authority to make the request) by:

• requesting that you provide personally identifying information, including your first name, middle name, last name, email address, shipping address and telephone number.

• requesting that you provide additional evidence proving your identity such as your unique customer identification number or details of a recent transaction.

You may make a verifiable consumer request up to two times within any 12-month period. We will not be able to respond to requests made more frequently than that. Right to Non-Discrimination for the Exercise of Consumer’s Privacy Rights You have a right not to receive discriminatory treatment from us for the exercise of any of your privacy rights conferred by the CCPA.

Your Right to Opt-Out As a California resident, you have the right to limit the personal information that we share with or sell to our affiliates or third parties. To request that your personal information not be sold, you may contact us online at: info@nomoscigars.com. In addition, customers who are California residents may request certain information regarding our disclosure of personal information to third parties for direct marketing purposes. To make such a request, please contact us at info@nomoscigars.com. Even if you opt out of the disclosures described in this section, we may still disclose information to affiliates and non-affiliated third parties as permitted by law.

CORRECTING YOUR INFORMATION If you are a registered user of the nomoscigars site(s), you may make changes or updates to certain information by logging into your password-protected account within the nomoscigarsI sites. Additionally, if you believe that information we maintain about you is inaccurate, subject to applicable law, you may request that we correct or amend the information by contacting us as indicated in the “Contact For More Information” section below.

Online Tracking Policy for California Residents As of the effective date of this Privacy Policy, there is no commonly accepted response for Do Not Track signals initiated by browsers and, therefore, we do not respond to them. Authorized Agent As a California consumer, you can designate an authorized agent to make a request under the CCPA on your behalf. To do so, please write to us at the address provided below, providing your full name and address, the name and address of your authorized agent, the agent’s contact information, specify your relationship with the authorized agent, and the purpose for which you are designating the authorized agent. You may revoke the authority of that agent at any time by contacting us in writing at the address below.

12. CHANGES TO THIS PRIVACY POLICY. We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected CompanyCollected PI, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

13. CONTACT COMPANY. Nomoscigars.com is owned and operated by CTJM, LLC. If you have any questions about this Privacy Policy, please contact Company by e-mail at info@nomoscigars.com .