Breeze's LogoPrivacy Policy

We at Copacabana Design USA, Inc.. (“Company,” “we,” “us,” “our”) offering our service called Breeze (“service”) know that our users (“you,” “your”) care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By visiting or using our website (“Website”) or our services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

I. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our Services. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register for our services we provide. If you are under 18, please do not attempt to register for our services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 may provide any personal information to us or on our services. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a person under 18, please contact us at legal@copa.design.

We gather various types of Personal Information from our users, as explained more fully below. We may use this Personal Information to personalize and improve our services, to allow our users to set up a user account, to contact users, to fulfill your requests for certain products and services, to analyze how users utilize our services, and as otherwise set forth in this Privacy Policy. We may share certain types of Personal Information with third parties, as described below.

II. WHAT INFORMATION DOES COMPANY COLLECT?

A. Information You Provide to Us: We receive and store any information you consent to provide us. For example, we collect Personal Information such as your name, email address, phone number, and company name. You can choose not to provide us with certain information, but then you may not be able to register with us or to take advantage of some of our features. We may anonymize your Personal Information so that you cannot be individually identified and provide that information to our partners.

If you have provided us with a means of contacting you, we may use such means to communicate with you. For example, we may send you promotional offers on behalf of other businesses or communicate with you about your use of our services. Also, we may receive a confirmation when you open a message from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by hitting unsubscribe in any email or contacting us at legal@copa.design. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of our services, and you are responsible for reviewing such legal notices for changes.

B. Information Collected Automatically: We collect Personal Informationto communicate with Website visitors, to customize content for visitors, to show ads on other websites to visitors, to send emails to visitors, and to improve its website by analyzing how visitors navigate its website. Whenever you interact with our website, social media, partner networks, events, and services, we automatically receive and record information on our server logs from your browser including your IP address, “cookie” information, and the page you requested. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your browser or mobile device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or mobile device to prevent or limit your computer or device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. If you click on a link to a third-party website, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.

When we collect usage information (such as the numbers and frequency of visitors to the Website), we only use this data in aggregate form, and not in a manner that would identify you personally. For example, this aggregate data tells us how often users use parts of our services, so that we can make our services appealing to as many users as possible. We may also provide this aggregate information to our partners; our partners may use such information to understand how often and in what ways people use our services, so that they, too, can provide you with an optimal experience. We never disclose aggregate information to a partner in a manner that would identify you personally.

Log data. We may collect log data, such as network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data.

Usage information. We may collect usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information), content interactions (including searches, views, downloads, and prints), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction, and similar data.

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through this Site or otherwise to us.

Use and Disclosure of Personal Data

Our primary goal in collecting, using, and sharing your information is to enhance and improve our Services. To that end, we will only use Personal Data for legitimate business purposes, including the following:

III. WHY DOES COMPANY COLLECT PERSONAL INFORMATION?

Our primary goal in collecting, using, and sharing your information is to enhance and improve our Services. To that end, we will only use Personal Information for legitimate business purposes, including the following:

Fulfillment of Requests. We may use Personal Information about you (a) to deliver products and Services to you, (b) provide you with information about products and Services you’ve ordered, (c) for internal research and development purposes, (d) when it is necessary for employees, agents and contractors to operate or maintain this Site or to correct a technical problem, (e) to detect and prevent fraud and abuse to ensure the security and protection of all customers and others, such as to verify the existence or condition of your account; (f) to comply with the law and our legal obligations, including to respond to a request or order from a court, regulator, or government authority; and (g) to effectuate the sale, merger, acquisition, or other disposition of our assets or business (including in connection with any bankruptcy or similar proceedings). We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation. Other Communications. From time to time, we may use Personal Information about you to inform you of products, programs, Services and promotions that we believe may be of interest to you. If you or your employer is one of our customers, we may also inform you of such products, programs, Services and promotions using Personal Information about you that you or your employer provided to us. If you would prefer that we not send electronic marketing messages to you, please see the “opt-out” section below. Promotions. We may operate sweepstakes, contests and similar promotions (collectively, “Promotions”). If you choose to enter the Promotions, we typically ask you for certain Personal Information when you enter and, if applicable, win a Promotion. You should carefully review the rules of each Promotion in which you participate, as they may contain additional important information about our use of Personal information about you. To the extent that the terms and conditions of such rules concerning the treatment of your Personal information conflict with this Policy, the terms and conditions of such rules shall control. We use this information to operate the Promotions. Other Business Purposes. We may also use Personal information about you for other business purposes, such as data analysis (for example, to improve the efficiency of our Site and Services), editorial and feedback purposes, providing customer support, customizing and improving the content and layout of this Site, completing business transactions (for example, to confirm content requested is received by users), development of marketing and promotion plans and materials, statistical analysis of user behavior (for example, to understand what parts of this Site are of most interest to users), product development, market research, administering individual accounts, and meeting government regulatory requirements such as sales tax collection, audits, etc. We may also use Personal information of journalist/media contacts for press release distribution or sharing other newsworthy developments related to our business activities. We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest. Administrative Communications. We reserve the right to use Personal information to send to you important information regarding this Site, products, Services, your account status, changes to this Site’s terms of use, this Policy, or any other policies, agreements or transactions relevant to your use of this Site, products and/or Services. Because this information may be important to your use of this Site, products and/or Services, you may not opt-out of receiving such communications. We will engage in this activity to manage our contractual relationship with you and/or to comply with a legal obligation.

IV. WILL COMPANY SHARE ANY OF THE PERSONAL INFORMATION IT RECEIVES?

We neither rent nor sell your Personal Information in personally identifiable form to anyone. However, we do share your Personal Information with third parties as described in Section II and in this Section:

A. Affiliated Businesses and Third-Party Websites We Do Not Control: In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through our services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.

B. Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

C. Business Transfers: We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.

D. Protection of Company and Others: We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

E. With Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties in personally identifiable form and will be able to prevent the sharing of this information. Inquires – You reserve the right to be informed about the use of your Personal Information and the right to object to processing your Personal Information that we’ve collected. If you wish to inquire about your Personal Information, we recommend that you contact the Data Control team at legal@copa.design.

V. IS PERSONAL INFORMATION ABOUT ME SECURE?

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Our services may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.

VI. WHAT PERSONAL INFORMATION CAN I ACCESS?

A. You may access, and, in some cases, edit or delete the following information you’ve provided to us by emailing us at legal@copa.design.

B. California Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to:

Copa Breeze, LLC. INSERT ADDRESS

To learn more about your California privacy rights, please see the attached Addendum or visit https://oag.ca.gov/privacy/privacy-laws.

VII. WHAT CHOICES DO I HAVE?

You can always opt not to disclose information to use, but keep in mind some information may be needed to register with us or to take advantage of some of our special features. You may be able to add, update, or delete information as explained in Section VI above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by contacting us at legal@copa.design. Please note that some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that could identify you personally.

VIII. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our website or sending you a message. You are bound by any changes to the Privacy Policy when you use our services after such changes have been first posted.

IX. QUESTIONS OR CONCERNS

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to legal@copa.design, and we will try to resolve your concerns.

X. GOVERNING LAW

Use of our Website is governed by United States law and the laws of the State of California. If you are accessing our Website or our services from a physical location outside of the United States with laws or regulations governing personal data collection, use, and disclosure that are different from United States laws, you agree that by accessing our Website, you are transferring your Personal Data and Other Data to the United States and you consent to the application of the laws of the United States and the State of California with respect to use of our Website and our services and any dispute regarding our Website or this Policy. You further consent to the exclusive jurisdiction of, and agree that venue is proper in, the state and federal courts located in San Francisco County, California; provided, however, that if the state and federal courts in San Francisco County, California are found not to have exclusive jurisdiction, then you agree to settle all disputes arising out of or relating to this Site or this Policy by binding arbitration in San Francisco, California in accordance with the International Arbitration Rules set by the International Centre for Dispute Resolution.

If any provision of this Policy is held by a court of competent jurisdiction to be illegal, unenforceable, or in conflict with any applicable law, the validity of the remaining portions or provisions shall remain in full force and effect.

Addendum: Privacy Notice for California Residents

Effective Date: August, 2022 Last Reviewed on: August, 2022 This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. Information We Collect Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, our Website has collected the following categories of personal information from its consumers within the last twelve (12) months: Category A: Identifiers Examples: A real name, Internet Protocol address, email address, or other similar identifiers. Collected: YES

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Collected: YES, with your consent Category C: Protected classification characteristics under California or federal law. Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: NO

Publicly available information from government records. De-identified or aggregated consumer information. Information excluded from the CCPA’s scope, like: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Use of Personal Information We may use, or disclose the personal information we collect for one or more of the following business purposes: To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. As described to you when collecting your personal information or as otherwise set forth in the CCPA. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. Disclosures of Personal Information for a Business Purpose In the preceding twelve (12) months, Copa has not disclosed personal information for a business purpose. Sales of Personal Information Copa does not, and in the preceding twelve (12) months, has not sold personal information. Your Rights and Choices The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. Access to Specific Information and Data Portability Rights You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: The categories of personal information we collected about you. The categories of sources for the personal information we collected about you. Our business or commercial purpose for collecting or selling that personal information. The categories of third parties with whom we share that personal information. The specific pieces of personal information we collected about you (also called a data portability request). If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions, by emailing us at legal@copa.design. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. Debug products to identify and repair errors that impair existing intended functionality. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. Comply with a legal obligation. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message to legal@copa.design. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. 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 data portability twice within a 12-month period. The verifiable consumer request must: Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information 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 information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

While Copa does not sell any personal information, you have the right, if you are 16 years of age or older, to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by sending us a message to legal@copa.design. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our Website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: Deny you goods or services. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. Provide you a different level or quality of goods or services. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email to legal@copa.design.

If you have any questions about this Policy or the practices of this Site, you can email us at legal@copa.design.