Privacy Policy

Nada Essentials Inc. Privacy Policy

UPDATED: January 1 2025 |EFFECTIVE: January 1 2025

Nada Essentials provides a service by which we provide useful products through app-enabled smart vending machines(the “Service”), using our mobile application (the “Mobile App”), and provide access to various associated websites, including www.nadaessentials.com (the“Websites”).

This Privacy Policy describes how Nada Essentials processes your information and explains the choices available to you with respect to your information in connection with the Service, the Mobile App and Websites. This Policy is current as of the Last Updated date set for thabove. We may change this Privacy Policy from time to time by posting the updated version of the Privacy Policy on our Service, Mobile App and Websites.If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal data we have previously collected from you, we will endeavor to give you reasonable notice in advance of such change by highlighting the change on our Service, Mobile App and Websites or notifying you electronically. You agree to periodically review our Privacy Policy to stay informed about how we process your personal data.

If you have any questions or concerns about how Nada Essentials processes your information or about this Privacy Policy,you can email us any time at privacy@nadaessentials.com. Additionally, if you’re looking to exercise your privacy rights, you can email us at privacy@nadaessentials.com.

What’s Changing With This Update

We updated our Privacy Policy to include information about relevant privacy and data protection laws and our business practices.

It’s important to us that you’re able to clearly understand how we process your information and what rights you have under privacy and data protection laws. We welcome any questions, concerns, or feedback you may have about the updates to this Privacy Policy.

Our Relationship With You

In situations where our users are subject to our Terms of Use to use Nada Essentials’ Service, Mobile App and Websites, Nada Essentials is the controller of the information.

Information We Process

Nada Essentials processes information we receive directly from you, both through your actions and through information automatically collected when you use Nada Essentials’ Service or Mobile App, or visit our Websites, and information collected by Nada Essentials from third parties. However, please note that this Privacy Policy does not apply to the processing of your information by third parties through your use of any third-party services available via our Service, Mobile App or Websites. Please visit those third-party websites directly for more information on their privacy and data protection practices.

Information Nada Essentials Receives Directly From You

This includes information that is needed for Nada Essentials to create an account for you, including one or more of the following:

Identifiers, including first and last name, company, email address, telephone number
Country, city, full address information
School attending
Personal information about you including birthday and gender
Information provided by you when you fill out forms or surveys, send messages or comments, or provide feedback to Nada Essentials

Information Automatically Processed When You Use Our Service, Mobile App Or Websites

Information related to your use of Nada Essentials’ Service, including the Mobile App and Websites, including:

· Unique identifiers assigned to you, name, birthday, gender, country, city

· Information about your device, including model and manufacturer and operating system

· Information associated with vending machines used by you

· Time of your particular interactions with the Service, Mobile App or Websites

· Identification of links and link text clicked and/or reviewed by you in the Service, MobileApp or Websites

· Identifiers and information associated with products seen or chosen by you

· Information about buttons and tabs pressed in the Mobile App or on the Websites

· QR codes scanned by you

· Information about your check out, including products chosen and dispensed to you

· Information about your interaction with advertising links

We may also collect the following:

Metadata and inference information related to your use of Nada Essentials’ Service, Mobile App and Websites, and third-party integrations to better understand the way you work in Nada Essentials’ platform and services. We may log the actions you take as you use Nada Essentials’ Service, Mobile App and Websites.
Internet network activity, cookies, and similar tracking technologies, including data our servers automatically record, including your web request, IP address, browser type and settings, referring/exit pages and URLs, number of clicks, location of clicks, interactions with our app and websites, behavioral metrics, heatmap data, session replay data, date and time stamp information, language preferences, and other such information. Please visit our Cookie Policy for more information about the types of information we collect via cookies, including information about advertising and analytics, and how we use it. To manage your cookies settings, you can adjust them in your browser as set forth in our Cookie Policy.
Information collected as a result of participation in beta testing, such as error reports or feedback provided by you.
Information about how you interact with our Service, our Mobile App, and our Websites, like nadaessentials.com, such as where you click, how long you visit a page, your scrolling, mouse hovers, and other data to help us better understand your experience and provide you with the best user experience.
Device information and activity when you use Nada Essentials via a mobile device, including the type of device you are using, device IDs, operating system version, and mobile network information to ensure that we are serving you the correct version of our application.
Derived device geolocation information, including approximate geographic location inferred from an IP address.

How We Use YourInformation

Nada Essentials uses your information to operate our products and services, including the Service, Mobile App andWebsites, communicate with you, process transactions where applicable, for security and fraud prevention, and to comply with the law. Specifically, we may process your information to:

Provide services to you and operate our business

Maintain, provide, and improve our products and services, including the Service, Mobile App and Websites
Help us better understand user interests and needs, and customize Nada Essentials for you
Analyze and research how you interact with our Service, Mobile App and Websites
Protect Nada Essentials and you, for example:some text
- Securing our systems and products against fraud or unauthorized activity
- Identifying, troubleshooting, and fixing bugs and errors
- Complying with global laws and regulations
Investigate in good faith alleged violations of our Terms of Use
Comply in good faith with a valid legal subpoenas, requests, or other lawful process

In addition, we use information about your use of Nada Essentials, account information (which may include your email address and name), to:

Communicate with you:some text
- About Nada Essentials by phone, text, email, or chat
- To provide important notices and updates, product changes, and other necessary notices such as security and fraud alerts
- To market Nada Essentials services to you. via email, phone, and mail. You have the ability to unsubscribe from promotional marketing communications at any time
Advertise Nada Essentials to you
Advertise products and services of Nada Essentials’ advertising partners to you
Facilitate reporting and analyze performance of the Nada Essentials platform and service or features available in Nada Essentials’ platform and service, including the Service, Mobile App and Websites
Provide webinars or public presentations
Demonstrate Nada Essentials
Process your information at your direction
Provide you with support and get your feedback:

· Respond to your requests for information

· Help identify and troubleshoot any issues with your account and answer your questions

· Resolve support requests

· Survey your opinions through surveys, research studies, and questionnaires

Combined Information

Unless otherwise prohibited by law, we may combine the information that we collect through your use of our products and services with information that we receive from other sources, both online and offline, and use that combined information as set out above.

Aggregated And De-Identified Data

We may aggregate and/or de-identify information related to your use of Nada Essentials so that such information can no longer be linked to you or your device. We may use such aggregated and de-identified data for any purpose, including but not limited to, research and marketing purposes and may also disclose such data to any third parties,including advertisers, promotional partners, sponsors, event promoters, and/or others.

How We Disclose Your Information

We need to disclose the information we collect about you to make our products and services run smoothly and to operate our business under the following conditions:

Service providers and sub-processors. We may provide access or disclose your information to select third parties, including third party private companies, that use the information on our behalf to assist in providing Nada Essentials’ services, websites, app and features. These third parties provide a variety of services to us, including without limitation sales, marketing, provision of content and features, advertising, analytics, research, data storage, security, fraud prevention, and other services.
Advertising partners. We may also provide information collected when you use or visit Nada Essentials Service, including the Mobile App and Websites, to our advertising partners, in order for them to assess the efficacy of product advertising carried out through Nada Essentials’ vending machines, and to further provide advertising and marketing of goods and services directly to you. In addition, we may provide such information to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit websites or apps. Our advertising partners may also use cookies and similar technologies on our website to display more relevant advertising on other websites or apps that you visit. Please see our Cookie Policy for more information about how we currently use targeting cookies and your options for managing them.
Because you ask us to disclose. We may disclose your information to third parties when you ask us to do so.
Business transfers. If the ownership of all or substantially all of our business changes, or all or some of our assets are sold as part of a merger, sale, divestiture, restructuring, financing, acquisition or other transfer, bankruptcy or other proceeding, we may transfer your information to the new owner so that the services can continue to operate, without prior notice to you. In such case, your information would remain subject to the promises and commitments contained in this Privacy Policy until the acquiring party updates it.
Compliance with legal obligations. To comply in good faith with a valid legal subpoena, request, or other lawful process. We will notify individuals or customers of that request unless: we are prohibited from doing so by law or court order; or there are exceptional circumstances, such as an emergency involving the risk of bodily injury or death to a person or group of people or potential harm to minors.

We use and disclose the categories of information we collect from and about you consistent with the various business purposes we discuss throughout this Privacy Policy. Our disclosure of information to third parties may include disclosure for their own direct marketing purposes.

The following is a list of sub-processors and third party entities [GR1] to which we disclose your information.

Entity Name| Subprocessing Activity |Entity Country

Amazon Web Services Inc. |Cloud hosting provider |U.S.

Google LLC| Google Analytics| U.S.

Protection, Storage,Transfer And Retention Of Your Information

Security

Nada Essentials takes technical and organizational measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. For example, we implement SSL encryption to protect your personal information. We are constantly updating and improving our safeguards and strive for the highest security standards. However, no method of transmission over the Internet and no means of electronic or physical storage is absolutely secure,so we cannot ensure or warrant the security of that information.

Storage

When you use Nada Essentials,information about you will be stored in the United States.

Data Retention

We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy,to make our products and services available to you, or as instructed by you,unless a longer retention period is required or permitted by law.

Other Important Information

Use By Individuals Under 18

We do not knowingly process any information provided from, or direct any of our products or services to, individuals under the age of 18.

Marketing Practices And Choices

If you receive email from us, we may use certain analytics tools, such as clear GIFs that capture data about your interaction with the email, which may include the date and time when you opened our email and whether you clicked on any links or banners within our emails.This data allows us to gauge the effectiveness of our communications and marketing campaigns.

You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, promotions, and special events that might appeal to your interests by contacting us via privacy@nadaessentials.com. In promotional marketing commercial email messages, you can also opt out by following the instructions located at the bottom of such emails or contact us at privacy@nadaessentials.com.

Please note that, regardless of your request, we may still use and disclose certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain transactional, operational, or service-related emails, including those reflecting our relationship or transactions with you.

Global Privacy Control And Do Not Track

Do Not Track is a privacy preference that users can set in certain web browsers and Global Privacy Control is an automated mechanism for notifying sites of user privacy preferences. We are committed to providing you with meaningful choices about the information collected on our websites for third party purposes, and that is why we provide the ability to opt out, if needed, and adjust your cookies preferences. We do not currently recognize or respond to browser-initiated DNT signals. Also, aswe do not currently engage in cross-contextual targeted advertising, we do not currently recognize or respond to Global Privacy Control signals. To learn more about Do Not Track, you can do so here. To learn more about Global Privacy Control (GPS), you can do so here. For more information about how Nada Essentials uses cookies and similar tracking technologies, visit our CookiePolicy.

Legal Bases For Processing Your Information

The laws in some jurisdictions require us to inform you of our legal bases for processing your information. Our legal bases for collecting and using your information described above will depend on the particular type of information and the specific context in which we collectit. However, some examples of legal bases for processing that we rely on:

Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with the Terms of Use which you accept by using Nada Essentials’ Service, Mobile App and/or Websites or to fulfill the terms of a contract signed with companies)
Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security, operate our products and services including the Service, Mobile App and Websites, prevent fraud, analyze use of and improve our products and services, and for similar purposes)
Where use of your information is necessary to comply with a legal obligation
Where we have your consent to process data in a certain way

Your Privacy Rights

We respect your ability to know,access, correct, export, restrict the processing of, and delete your information. We will not discriminate against you for exercising your privacy rights.

Information About Your Rights

Upon your request, and subject to applicable legal exceptions, we will:

provide access to and/or a copy of certain information we hold about you
provide you with information about categories of information we collect or disclose about you, the categories of sources of such information, the business or commercial purpose for collecting your information, and the categories of third parties to which we disclose your information. For your convenience and so you don’t have to request it, we’ve included that information in this Privacy Policy.
prevent the processing of your information for promotional purposes (including any direct marketing processing based on profiling)
update information which is out of date or incorrect
delete certain information which we have about you
restrict the way that we process and disclose some of your information
transfer your information to a third party provider of services
revoke your consent for the processing of your information

If you request these rights, we will need to verify your identity and may need to verify your relationship with Nada Essentials for security and to prevent fraud. You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, the authorized agent must present signed, written permission to make such requests or a power of attorney. We may also contact you to verify your identity before processing the authorized agent’s request.

We may take additional steps to verify that you are authorized to make the request. To exercise your privacy rights,please make a request by emailing privacy@nadaessentials.com.

Please note, however, that certain information may be exempt from such requests in some circumstances (for example, if we need to keep processing your information for our legitimate interests or to comply with a legal obligation). Depending on applicable law,you may have the right to appeal our decision to deny your request. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.

Right To Manage Cookies Preferences

As explained in detail in our CookiePolicy, we provide information about how we use cookies and similar technologies. If you would like to opt out of use of certain cookies, you can adjust them in your browser as set forth in our Cookie Policy.

Right To Opt-Out Of Sales Of Your Information

We offer financial incentives to you,in the form of free products, in exchange for your personal information. We also provide your information to our third-party advertising partners as part of the services we provide for them, in exchange for financial compensation. We provide this information so that our advertising partners can assess the efficacy of their advertising on products distributed through our vending machines and to enable them to offer goods and services to you through direct advertising or marketing efforts. This provision of information to our advertising partners constitutes a “sale” of your information under applicable law. You may opt out of sale of your personal information, but if you do so you may not receive valuable offers and advertisements of interest to you and tailored to your preferences. If you wish to opt out, you may click on the “Do Not Sell My Personal Information” link inour Mobile App or Websites,[GR2] or email us at privacy@nadaessentials.com.

Privacy Information for California, Colorado, Connecticut, Montana, Oregon, Texas, Utahor Virginia Residents

Categories of information collectedand disclosed

If you are a resident of California,Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia, we adopt this notice to comply with applicable consumer privacy laws of those states,including without limitation the California Consumer Privacy Act of 2018 (CCPA)and California Privacy Rights Act of 2020. We will continue to evaluate and update this notice as the state privacy laws, related regulations, and general understanding of their complexities and ambiguities evolve. You have certain rights under the foregoing state laws, and we want to provide you with the following additional information about the purpose for which we use each category of personal information we collect, the categories of third parties to which we disclose personal information for a business purpose or forcross-context behavioral advertising, which includes our use of third-party analytics services and online advertising services. These are described in detail in our Cookie Policy and may result in the disclosure of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) and are described throughout this Privacy Policy.

Specifically, your account and usage data, your contact information (including email) or internet network and deviceinformation (including cookie data and IP address) may be disclosed to online advertising and analytics partners. Your right to opt-out of sales of your information and to opt-out of cookies and similar technologies are described above in the Your Privacy Rights section of this Privacy Policy. Our current practices in this regard are described above in this Privacy Policy and in our CookiePolicy.

For more information about each category of personal information, purpose of use, and third parties to which we disclose personal information, please see the Information We Process, How We Use Your Information, and How We Disclose Your Information sections of our Privacy Policy.

Other rights

The state laws also allow you to limit the use or disclosure of your sensitive personal information (e.g., without limitation, social security, driver’s license, state identification card,passport number, account log-in, financial account number, debit card number or credit card number, biometric information), if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information.

Please see the Your Privacy Rights section of our Privacy Policy above for information about the additional rights you have with respect to your personal information and how to exercise them.

Retention of your personal information

Please see information under DataRetention in the Protection, Storage, Transfer and Retention of Your Information section of our Privacy Policy.

California “Shine the Light”disclosure

The California “Shine the Light” lawgives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure. We do not currently disclose your personal information to third parties for their own direct marketing purposes.

Nevada rights

Under Nevada law, certain Nevada consumers may opt out of the sale of information about you. We do not sell your data in accordance with Nevada Senate Bill 220. However, if you are a Nevada resident you may submit a request to opt out of any potential future sales under Nevada law by contacting us at privacy@nadaessentials.com. Please note,if needed, we may take reasonable steps to verify your identity and the authenticity of the request.

Changes To Our Privacy Policy

We will update this Privacy Policy to make sure it accurately reflects our data collection and use practices, our features, advances in technology, or as applicable laws require. We will comply with applicable legal requirements regarding providing you with notice and/or consent when we make such changes, depending on the type of change made. We also provide information about how our Privacy Policy has changed over time below.

Contact Us and Privacy Questions

Nada Essentials is located at 270 Sylvan Ave, Suite 2260, Englewood Cliffs, New Jersey 07632.If you wish to contact us or if you have any questions about or complaints in relation to this notice or wish to contact our Data Protection Officer, please contact us at privacy@nadaessentials.com.

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