Last Modified: July 03, 2018

1. Purpose and Scope

The purpose of this Privacy Policy is to inform you of the purposes for which we collect and use Personal
Data, the types of Personal Data we collect, the types of third parties to which we may disclose your
Personal Data and the purposes for doing so, the rights and choices you have for limiting the use and
disclosure of your Personal Data, and how to contact us about our practices concerning Personal Data.

This Privacy Policy applies to the Personal Data of individuals who seek to be, are, or were customers of
Inga, LLC (“Customers”) or who visit our website (“Site Visitors”), including any Personal Data of
individuals collected, used, or disclosed (a) while using the Company website,
(“Website”) and (b) in email, text, and other electronic messages between us.

This Privacy Policy does not apply to information collected by us offline, on a website operated by a third
party (including our affiliates and subsidiaries), or by a third party, including through an application or
content (including advertising) that may link to or be accessible from our website.

When we refer to “Company” “we” or ‘us” in this Privacy Policy, we are referring to Inga, LLC.

Please read this policy carefully to understand our policies and practices regarding your information and
how we treat it. If you do not agree with our policies and practices, your choice is to not use our Website.
By accessing or using this website, you agree to this Privacy Policy.

      1.1. Inquiries or Concerns?

We are committed to resolving complaints about our collection or use of your Personal Data. Individuals
with inquiries or complaints regarding our Privacy Policy should first contact us at We will endeavor to answer your questions and advise you of any steps taken
to address the issues raised by you.

      1.2. Revisions to this Privacy Policy.

We may revise this Privacy Policy to reflect changes in our legal or regulatory obligations or in the
manner in which we deal with your Personal Data. It is our policy to post any changes we make to our
privacy policy on this page and such changes will be effective from the time they are posted, provided
that any material change to why we collect, use, or disclose your Personal Data will not apply to you,
where your consent is required to such collection, use or disclosure, until we have obtained your consent
to such change.

      1.3. Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide
Personal Data to the Website. We do not knowingly collect Personal Data from children under 16. If we
learn we have collected Personal Data from a child under 16 without parent consent, we will delete that
information. If you believe we might have information from or about a child under 16, please contact us.

2. Our Policies

      2.1. Notice

            2.1.1. What is Personal Data?

For the purposes of this Privacy Policy, Personal Data is information, including Sensitive Data, that is: (i)
about an identified or identifiable individual, (ii) received by us, and (iii) recorded in any form. Personal
Data does not include anonymous or non-personal information (i.e., information that cannot be associated
with or tracked back to a specific individual). “Sensitive Data” means Personal Data specifying medical
or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for
any offense committed or alleged to have been committed by the individual or the disposal of such
proceedings, or the sentence of any court in such proceedings.

      2.1.2. Personal Data We Collect and How We Collect It

We may collect and maintain Personal Data regarding Site Visitors and Customers, including information
by which you may be personally identified, such as your name, postal address, e-mail address, telephone
number, credit card or bank account information, or any other identifier by which you may be contacted
online or offline; that is about you but individually does not identify you, such as your Internet Protocol
(“IP”) address; and about your internet connection, the equipment you use to access our Website and
usage details, and the actions you take on our website.

We collect this information:


  1. Directly from you when you provide it to us, see Information You Provide Us;
  2. Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
  3. From third parties, for example, our business partners and service providers, including Shopify, Instagram, Facebook.


      2.1.3. Information You Provide Us


The information we collect on or through our Website may include information that you provide by filling
in forms on our Website. This includes information provided at the time of registering to use our Website,
purchasing product, posting material, requesting further services, or corresponding with us. We may also
ask you for information when you enter a contest or promotion sponsored by us, and when you report a
problem with our Website.

      2.1.4. Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website and other content, we may use automatic data
collection technologies to collect certain information about your equipment, browsing actions, and
patterns, including:


  1. Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  2. Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and
across third-party websites or other online services (behavioral tracking). We do not honor Do Not Track

The information we collect automatically may include personal information, or we may maintain it or
associate it with personal information we collect in other ways or receive from third parties. It helps us to
improve our Website and to deliver a better and more personalized service, including by enabling us to:


  1. Estimate our audience size and usage patterns;
  2. Store information about your preferences, allowing us to customize our Website according to your individual interests;
  3. Speed up your searches; or
  4. Recognize you when you return to our Website.


The technologies we use for this automatic data collection may include:


  1. Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  2. Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  3. Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

      2.1.5. Our Purposes in Collecting Personal Data?

The Personal Data we collect is used and disclosed as is necessary to provide services to you and as
reasonably required for our business purposes, including:


  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent as required by applicable law.

      2.1.6. Types of Third Parties That May Receive Your Personal Data

We may disclose aggregated information about our users without restriction. Such information does not
identify an individual person.

We may disclose Personal Data to the following types of third parties:

Service Providers
We may share Personal Data with our contracted service providers, such as billing or payment processors,
so that these service providers can provide services on our behalf. Unless described in this Privacy Policy,
we do not share, sell, rent, or trade any information with third parties for their promotional purposes.

Subsidiaries and Affiliates
We may share Personal Data with other members of the Company corporate group in order to work with
them, including affiliates of the Company corporate group. For example, Company may need to share
Customer Information for customer relationship management purposes. We may also transfer Personal
Data in the event of an audit or if we sell or transfer all or a portion of our business or assets (including in
the event of a merger, acquisition, joint venture, reorganization, dissolution, or liquidation).

Partners and Affiliated Businesses Not Controlled by Company
We may partner with other companies to jointly offer products or services. If you purchase or specifically
express interest in a jointly offered product or service from us, we may share Personal Data collected in
connection with your purchase or expression of interest with our partners. We contractually require these
third parties to keep Personal Data confidential and use if only for the purposes for which we disclose it to
them. If you do not wish for your information to be shared in this manner, you may choose not to
purchase or specifically express interest in a jointly offered product or service.

Compelled Disclosure
It may be necessary for us to disclose your Personal Data, either by law, legal process, litigation, or
requests from public and governmental authorities. We may also disclose information about you if we
determine that for purposes of national security, law enforcement, or other issues of public importance,
disclosure is necessary or appropriate. We may also disclose Personal Data if we determine that disclosure
is reasonably necessary to enforce our terms and conditions or protect our operations or users.

      2.2. Rights and Choices 

            2.2.1. Choice

We offer Site Visitors and Customers who provide Personal Data the means to choose how we use the
information we collect. To the extent required by applicable law, Company obtains opt-in consent for
certain uses and disclosures of Personal Data. You have a right to withdraw such consent at any time. We
shall make reasonable efforts to accommodate individual privacy preferences.

Account Profile
To update your account information or have your account deleted, please email To discontinue your account, please email
Requests to access, change, or delete your information will be handled within 30 days.

Tracking Technologies
You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being
sent. For Flash, to learn how you can manage your Flash cookie settings, visit the Flash player settings
page on Adobe’s website. Not all browser refusal settings may be effective however. If you disable or
refuse cookies, please note that some parts of the Website may then be inaccessible or not function

Promotional Offers
If you do not wish to have your information used by the Company to promote our own or third parties’
products or services, you can opt-out by checking the relevant box located on the form on which we
collect your data. You may send a request specifying your communications preferences to Customers cannot opt out of receiving transactional emails related to their
account with Company or the Services.

We do not control third parties’ collection or use of your information to serve interest-based advertising.
However these third parties may provide you with ways to choose not to have your information collected
or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising
Initiative (”NAI”) on the NAI’s website.

Exceptions. We may disclose your Personal Data without offering an opportunity to opt out, when (i) we
retain third-party processors to perform services on our behalf and pursuant to our instructions, (ii)
required by law or legal process, or (iii) responding to lawful requests from public authorities, including
to meet national security, public interest, or law enforcement requirements.

      2.2.2. EU Persons

Limited Processing
We limit the processing of Personal Data of persons in the EU (“EU Personal Data”) to that which is
relevant for the purposes of the particular processing. We do not process EU Personal Data in ways that
are inconsistent with the purposes for which the information was collected or subsequently authorized by

In addition, to the extent necessary for these purposes, we take reasonable steps to ensure that the EU
Personal Data we process is (i) reliable for its intended use, and (ii) accurate, complete and current. In this
regard, we rely on you to update and correct EU Personal Data to the extent necessary for the purposes for
which the information was collected or subsequently authorized. You may contact us at to request that we update or correct relevant EU Personal Data.

Subject to applicable law, we retain EU Personal Data in a form that identifies or renders you identifiable
only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data
was collected or subsequently authorized by you.

Notice and Consent
If we decide to process EU Personal Data for purposes other than what is necessary to provide services to
you or where we believe that your interests may override ours, persons in the EU will receive a notice


  1. the type of Personal Data to be processed;
  2. the purpose for the processing and a description of how the processing is based on legitimate interests;
  3. the categories of recipients of disclosures of the Personal Data;
  4. the period for which the Personal Data will be stored or the criteria for determining the period;
  5. how Customers and Site Visitors can exercise the rights of access, correction, erasure, objection, and the right to withdraw consent;
  6. the right to file a complaint with an EU Data Protection Authority;
  7. whether the Customer or Site Visitor is obliged to provide the data by statute, contract, or for another reason, and the possible consequences of failing to provide the data; and
  8. whether the Personal Data will be subject to automated processing and, if so, the logic and the consequences of the processing for the data subject.

Such notices will be clear, conspicuous, and readily available to affected EU Persons. A notice will
require an unambiguous, affirmative, opt-in consent to the particular use or processing of the EU Personal

      2.2.3. Access

You generally have the right to access your Personal Data. Accordingly, where appropriate, we provide
you with reasonable access to the Personal Data we maintain about you. We also provide you a reasonable
opportunity to correct, amend, or delete your information.

We may limit these opportunities where the burden or expense of honoring a request would be
disproportionate to the risks to your privacy, or where the rights of persons other than you would be
violated. Other reasons for denying requests or limiting access include (i) interference with the execution
or enforcement of the law or with private causes of action, including the prevention, investigation, or detection of offenses; (ii) breaching a legal or other professional privilege or obligation; (iii) prejudicing
security investigations or grievance proceedings or in connection with succession planning and corporate

Please contact to request access to your Personal Data. If access cannot be
granted, Company will respond with a reason for denying your request.

      2.2.4. Grievance procedure

You may file a complaint concerning Company’s processing of Personal Data by email at If a failure to comply with this Privacy Policy or other obligations, we will
take steps to remedy the issue.

If a complaint regarding Personal Data cannot be resolved through our internal processes, we will
cooperate with applicable data protection authorities to address a complaint and provide appropriate

      2.3. Control and Security

            2.3.1. Integrity and Confidentiality

We take reasonable and appropriate measures to secure your personal information from accidental loss
and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where
you have chosen) a password for access to certain parts of our Website, you are responsible for keeping
this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do
our best to protect your personal information, we cannot guarantee the security of your personal
information transmitted to our Website. Any transmission of personal information is at your own risk. We
are not responsible for circumvention of any privacy settings or security measures contained on the

      2.3.1. Data Breach

If a breach of Personal Data occurs, we will notify the relevant authorities within 72 hours, or as
otherwise required by applicable law, subject to likelihood of risk to the Customer or Site Visitor.
Affected Customers or Site Visitors will also be notified regarding the breach.

      2.3.2. Record-keeping

As required by applicable law, we will maintain relevant records of the purposes of Personal Data
processing; the categories of data subjects and of Personal Data processed; the categories of recipients,
including those in third countries; the countries to which Personal Data will be transferred and the
instrument used to provide an adequate level of protection; where possible, the envisaged retention
periods for different categories of Personal Data; and a general description of the security measures used
to protect Personal Data. These records shall be provided to data protection authorities upon request.