JAMIE BLACK TOP

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Color	Black

PRIVACY POLICY

Last Updated: April 30th, 2017

1. INTRODUCTION

AGREEMENT AND PARTIES. Westernfordsaigon LLC (“Company,” “us,” or “we”) respects the privacy of the visitors to the Company website https://www.westernfordsaigon.com (“Website” or “Site”). This Privacy Policy (“Privacy Policy” or “Policy”) is an agreement between us and our Website and you, as the user of the Website (“you”). This agreement tells you when this Policy is effective, what information we collect from you, how we might use it, how you can review or change the Personal Information you provided to us, how we may change this Policy, and the steps we take to ensure that your Personal Information is protected. This site is published and maintained on behalf of the Company with offices located at Mannerheimintie 14 Rancho Santa Fe CA 92067

This policy applies to information we collect through any medium, including, but not limited to information:

• On this Site and all associated pages and subpages
• In email, text, and other electronic messages between you and the Site
• Through mobile and desktop applications you download from this Site, which provide dedicated non-browser-based interaction between you and this Site
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy

It does not apply to information collected by:

• Us offline or through any other means, including on any other Site operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries) including through any application or content (including advertising) that may link or be accessible from or on the Site

2. AGREEMENT TO TERMS OF PRIVACY POLICY AND TERMS OF USE

AGREEMENT TO TERMS. All activities in which you may engage on this Website are voluntary. You are not required to provide any Personal Information to us unless you choose to access this Site and/or the features on the Site that require your Personal Information. If you do not agree with the terms of this Policy or other Terms of Use on this Website, then you should immediately exit this Website and discontinue using the Site. If you do not agree with the terms of our Privacy Policy and/or our Terms of Use posted at https://www.westernfordsaigon.com/pages/privacy-policy, please do not provide us with any Personal Information, and leave this Website. The Terms of Use of this Site are expressly incorporated herein by reference and made a part of this Policy. 

3. EFFECTIVE DATE OF AND CHANGES TO PRIVACY POLICY

EFFECTIVE DATES. This Privacy Policy is effective as of May 8, 2017 and will remain in effect except with respect to any of its provisions that are changed in the future, in which case the changes will become effective on the date they are posted on the Website or we otherwise notify you of the changes. We reserve the right to change this Privacy Policy at any time. Changes, modifications, additions, or deletions will be effective immediately on their posting to this Site. You should check this Policy periodically as its terms may change from time to time. Your continued use of the Site after we post any such modifications will constitute your acknowledgment of the modified Policy and your agreement to abide and be bound by the modified Policy. We will also revise the “last updated” date found at the beginning of this Privacy Policy when we post changes to it.

4. POLICY APPLICABLE TO ONLINE ACTIVITIES ONLY

DISCLAIMERS. The Privacy Policy does not extend to anything that is inherent in the operation of the Internet, and therefore beyond Company’s control, and is not to be applied in any manner contrary to applicable law or governmental regulation. This online Privacy Policy only applies to information collected through this Site. This Privacy Policy does not apply to any information we may collect from you in any place other than this Website.

5. PERSONAL INFORMATION WE MAY COLLECT

TYPES OF INFORMATION COLLECTED. We may ask you for certain information referred to on this Site as “Personal Information,” which includes information that pertains to your identity. Such information may include, but is not limited to, items such as your name, address, date of birth, age, gender, e-mail address, telephone number, or credit card or debit card number information. You may be required to provide Personal Information to access or use certain parts of our Website or features of the Site. If you do not provide the requested Personal Information, you may not be able to access or use the features of the Site where such information is requested. This Site will also collect information about you but does not individually identify you.

6. GENERAL INFORMATION WE MAY COLLECT

TYPES OF INFORMATION COLLECTED. There may be other instances in which we collect information from you that is more general in nature (“General Information”). Such information may include your Internet Protocol (IP) address, which enables us to identify your computer or device on a Transmission Control Protocol/Internet Protocol (TCP/IP) network, which includes the World Wide Web. Your computer has an IP address, which is required in order for you to communicate with others via the Internet. Such General Information, including the “Click Stream Data” (defined below) and cookies, as mentioned below, may be collected from you whenever you access the Site, whether or not you provide us with any Personal Information.

6.1. Click Stream Data

When you visit our Website we may also collect “Click Stream Data” (server address, domain name). This information can be combined with information you have provided to us by registering, for example, which will enable us to analyze and better customize your visits. We may use Click Stream Data for traffic analysis or e-commerce analysis of our Website, to determine which features of our Site are most or least effective or useful to you.

6.2. Cookies

A cookie is a small string of information that the Website you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity on the Website and that information helps us to understand your preferences and improve your Website experience. We may also use cookies to gather information about your visits to our Website and enhance your experience. More information on how we use cookies is available in the section “Use of Cookies.”

6.3 Clear GIF’s

We may use “clear GIFs” (aka “Web beacons” or “pixel tags”) or similar technologies, in the Site and/or in our communications with you to enable us to know whether you have visited a Web page or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a Web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual’s viewing or receipt of a Web page or message. A clear GIF may enable us to relate your viewing or receipt of a Web page or message to other information about you, including your Personal Information.

6.4 How We Respond to “Do Not Track” Disclosures

We are strongly committed to not sharing non-public information with third parties. Under this Privacy Policy, we may share your information only under particular situations, as described in this Policy. Because we protect all users in this manner, we do not change our behavior in response to a web browser's “do not track” signal.

6.5 Geolocation

We may utilize geolocation (identifying your geographical location by means of digital information that is processed through the internet) to track visitors to our Website. Geolocation is used to track the number of visitors to our Website which may be accessible by third parties and for marketing purposes.

7. GENERAL INFORMATION YOU PROVIDE US

There are instances in which you will provide information to the Company and the information we collect on or through our Site as a result may include:

• Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to our service posting material or requesting further services. We may also ask for your information when you enter a contest or promotion sponsored by us, and when you report a problem with our Site.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Site and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Site.
• Your search queries on the Site.

You also may provide information to be published or displayed on public areas of the Site, or transmitted to other users of the Site or third parties (collectively “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

8. GENERAL INFORMATION ABOUT YOU

USE OF GENERAL INFORMATION. We will primarily use the Personal Information you provide and any General Information we receive from you to provide products and services to you, including, but not limited to, the following:

1. To administer a content promotion survey or other Site and to provide you with the relevant products or services (for example, to deliver a prize you may have won in a contest).
2. To send you information or materials via e-mail about products, offers, and news we think might interest you. This information may relate to products, offers, and news of Sunny Co or its licensees or selected commercial partners. We send you this only if you have single-opted-in to receive e-mails from our Website. A single-opt-in occurs when you only need to submit your email address to register for our Website and subscribe to any related mailings. If you no longer wish to receive any e-mails from us, or if you want to modify your personal data or want your personal data to be deleted from our database, see Section 14.
3. To analyze visits to the Website and learn about the interests of our visitors in aggregate and also on a personal level to better understand your interests and needs, so we can improve our products and services and deliver to you the type of content, features and promotions that you are most interested in.
4. PROTECTION OF YOUR PERSONAL INFORMATION AND GENERAL INFORMATION

9.1. Security Measures

We have implemented appropriate security measures in order to protect both the Personal Information and the General Information that we receive from you through our Website.

9.2. Risk of Interception

Please keep in mind, however, that whenever you give, or have Personal Information collected online there is a risk that third parties may intercept and use that information. While the Company Website strives to protect your Personal Information and privacy, we cannot guarantee the security of any information you disclose online. By using this Site, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us through this Site and that any Personal Information, General Information, or other data or information received from you through the Site is provided to us at your own risk, which you expressly assume.

10. RIGHT TO OPT IN AND OPT OUT

You have the right to “opt in” and “opt out” of certain of our uses of your Personal

Information, you may elect to “opt out” by selecting the “unsubscribe” button located on the bottom of any newsletter or associated marketing materials, you may also opt-out by contacting us at [email protected] or by submitting a request in writing to Westernfordsaigon LLC located at Mannerheimintie 14 Rancho Santa Fe, 39930, Finland, (+358)228638536 Attn: Compliance Department. At the time you are requested to provide Personal Information on this Site, you will have the opportunity to elect to, or not to: (1) receive correspondence from us, or (2) have your Personal Information shared with other entities for their marketing purposes. Users may opt not to receive our electronic newsletters or those of third parties when providing Personal Information. Users who opt in may remove themselves from mailing lists at any time through the account-management pages or by following the instructions at the end of the e-mail they received from us.  If you opt not to provide certain Personal Information when registering for or using our Site, however, you may not be able to use some of our services such as message boards.

Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.  Also, a request to have us stop sharing your Personal Information with other entities for marketing purposes will only apply as of the date of your request, and we will not be responsible for any communications that you may receive from entities that received your Personal Information prior to such request. In these cases, please contact that entity directly.

11. NO USE OF THIS SITE BY PERSONS UNDER 18 PERMITTED

11.1. Registration Declined

The Company Website intends only persons who are 18 years or older to use this Website. Personal registration information submitted by a person under the age of 18 will not be accepted. Any General Information provided by a person under the age of 18 and gathered (for example, through the use of cookies) during his or her visit may be used as indicated in this Policy (see Section 6). Company is committed to protecting the privacy of children and has no intention of collecting personal data from children under the age of 18. We strongly encourage parents and guardians of children under 18 to regularly check and monitor their children’s use of e-mail and other activities online.

11.2. Notice Concerning Children

PLEASE NOTE: We are a general audience Site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we are given notice or have reason to suspect that a Site user is under age 13, we will timely delete any Personal Information in that user’s account.

12. THIRD PARTIES

12.1. Sharing Information With Persons or Entities Who Manage This Website

Company’s global and local Websites and the Personal Information and General Information collected are managed and controlled by Westernfordsaigon LLC located at Sunny Co Mannerheimintie 14 Karvia, 39930, Finland, (+358)228638536 The servers that make Company’s global and local Websites available are located in Karvia. If you are located outside Karvia, please note that the information you provide will be transferred to Westernfordsaigon LLC, and by submitting the information you authorize this transfer. Sunny Co has entered into an agreement with the hosting company in location to provide safeguards for the protection of your data that are consistent with this Policy.

12.2. Disclosing Information to Third Parties

WHO MAY HAVE ACCESS TO YOUR INFORMATION. Other than to the companies belonging to, or affiliated with Company for the purposes set out above, and except as described in this Policy, we do not sell, trade, or otherwise transfer your Personal Information or General Information to third parties without informing you in advance. We provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties (collectively, “Service Partners”). Our Service Partners may use your Personal Information to operate our Sites and to deliver their services. For example, your data may be transferred to Website hosting partners and other parties who assist us in designing and operating the Website, executing services (such as for prize fulfillment), or helping us analyze collected data. These parties will only use your data for the purpose of carrying out the work as agreed with us and will be required to keep the information confidential. We will encourage our Service Partners to adopt and post privacy policies. However, the use of your Personal Information by our Service Partners is governed by the privacy policies of those Service Partners and is not subject to our control. Please also see Paragraph 6.4 on how we will respond to “do not track” signals.

12.3. Security

RELEASE OF INFORMATION. Company will release Personal or General Information without your consent for security purposes, when required by law, or to prevent imminent harm to any person or entity. We will disclose Personal or General Information upon receipt of a court order or subpoena, or to cooperate with a law enforcement investigation, which may include responding to requests and court orders from jurisdictions outside the United States. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful, as determined in our sole discretion. Release of your personal data or Personal Information for security purposes, as described in this agreement to any person or entity under any circumstances shall be based on a determination made solely by us, exercising our own discretion, permission for which is expressly granted by you to us in accordance with this Policy.

California Civil Code Section § 1798.83 permits users of our Site 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 an e-mail to [email protected]

12.4. Links to Third Parties

PURPOSE OF LINKS. For your convenience and to improve the usage of the Website we may insert links to third parties on this Site. This Privacy Policy does not apply to such third party Websites. These links take you outside our service and off the Company’s Site and are beyond our control. This includes links from partners that may use Company logos as part of a co-branding agreement. The Sites those links can take you to have their own separate Privacy Policy and although we seek to protect the integrity of our Site, Company is not liable for the content and activities of those third party sites and links. Your visits and access to such websites are at your own risk. Please note that those other sites may send their own cookies to users, collect data, or solicit Personal Information that is outside the scope of what we collect on our Site.

13. AUTOMATIC COLLECTION

COOKIES. In addition to Section 6.2 above, cookies are also used for such activities as remembering your user name and password, if you use such a feature on this Site. You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options you have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the functionality of the Website you visit and you may lose access to some of its features.

14. DELETING OR MODIFYING PERSONAL INFORMATION

CHANGING YOUR INFORMATION. You may cancel your account or any associated registration information at any time, and you may opt out of receiving any e-mails from Company. Additionally, you can choose to have all your Personal Information deleted from our database. You may opt out, or delete or modify your Personal Information, by contacting us at [email protected].

15. QUESTIONS OR COMMENTS

CONTACT INFORMATION. If you have any questions or comments relating to our Website or the Privacy Policy, send an e-mail to [email protected] or write Attn: Privacy Compliance Officer, Westernfordsaigon LLC, Mannerheimintie 14 Karvia 39930, Finland