Last Updated: June 23, 2020

The Genius Creative Adventures, LLC respects your concerns about privacy. This Privacy Policy describes the types of personal information we obtain about consumers and other individuals identified below, how we may use the information, with whom we may share it, and the choices available regarding our use of the information. The Privacy Policy also describes the measures we take to safeguard the personal information and how individuals can contact us about our privacy practices.

This Privacy Policy applies to personal information we obtain about you, including through (1) your use of our website, mobile sites and mobile applications (“Online Channels”), (2) your visits to our stores and contacts with us via telephone, at our events and through surveys, and (3) your interactions with e-commerce sites on which our products are sold. This Privacy Policy does not apply to activities that have a separate privacy policy that does not incorporate this Privacy Policy.

We have the right to update our privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

I. Information We Collect

The Genius Creative Adventures obtains personal information about you, including:

• Contact information, such as name, phone number, and email and postal address;
• Account information, such as online password and other log-in details used to access Genius Creative Adventures products and services;
• Payment information, such as name, billing address and payment card details, including card number, expiration date and security code;
• Location data (such as data derived from your IP address, country and/or ZIP code) and, with your consent, the precise geolocation of your mobile device;
• Social media handles, content and other data posted on our official social media pages;
• Information we obtain from third-party social media services (e.g., Facebook) or payment services (e.g., PayPal) if you choose to link to, create or log into your Genius Creative Adventures account through these services;
• Demographic and preference information (e.g., date of birth, gender, dietary preferences, allergies and favorite categories) and health quiz responses;
• Information you submit in connection with a career opportunity at Genius Creative Adventures, such as contact details, information in your résumé (including work history, education and language skills) and details about your current employment. In addition, where legally permissible, you may choose to provide information about your gender, race and ethnicity, and veteran and disability status;
• Contact information you provide about friends or other people you would like us to contact; and
• Other personal information contained in content you submit to us, such as through our “Contact Us” feature or customer support tools on the Online Channels.

Information We Obtain by Automated Means
When you interact with our products and services, we obtain certain information by automated means, such as cookies, web server logs, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We may use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, Internet service provider, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, dates and times of visits to the Online Channels, number of links you click while using the Online Channels, search terms, operating system, website traffic and related statistics, keywords and other data about your device and use of the Online Channels. These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with our products and services; (3) tailor the services around your preferences; (4) measure the usability of our products and services and the effectiveness of our communications; and (5) otherwise manage and enhance our products and services, and help ensure they are working properly.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of the Online Channels. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

II. How We Use The Information We Collect

We may use the personal information we obtain about you to:

• process and fulfill orders and purchases via the Online Channels and keep you informed about the status of your order;
• establish and manage your account;
• identify and authenticate you so you may order our products and access and use the Online Channels;
• provide customer and technical support and respond to inquiries;
• communicate with you regarding news updates, notices, special promotional offers, advertisements and marketing materials, our products and services, or other information that may be of interest to you;
• communicate about, and administer participation in, special events, programs, promotions, offers, surveys, focus groups and market research;
• communicate about, and administer participation in, special events, programs, promotions, offers, surveys, focus groups and market research;
• notify you about product safety and recall information, such as reporting an adverse event or communicating a product recall;
• manage career opportunities, including for recruitment purposes, employee on boarding and other human resources purposes;
• increase and maintain the safety and security of our products and the Online Channels and prevent misuse;
• operate, administer, evaluate, develop, manage and improve our business (including operating, administering, analyzing and improving our products and services; developing new products and services; performing analytics (including market research, trend analysis, financial analysis, and anonymization and aggregation of personal information); managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing reconciliation and collection activities and other internal functions);
• protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
• comply with and enforce applicable legal requirements and relevant industry standards and policies, such as this Privacy Policy and our Terms of Use.

We also may use the information we collect about you in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law.

Third-Party Analytics Services
We may use third-party web analytics services in connection with the Online Channels, such as Crazy Egg (privacy policy available at: https://www.crazyegg.com/privacy), Google Analytics, Optimizely and SOASTA mPulse and other analytics providers. These service providers use automated technologies to collect data (such as IP addresses) to evaluate use of the Online Channels. To learn more about Google Analytics’ privacy practices, please visithttps://www.google.com/intl/en/analytics/learn/privacy.html.To opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout. To opt out of Crazy Egg analytics, please visit https://www.crazyegg.com/opt-out

Online Tracking and Interest-Based Advertising
On our Online Channels, we may collect information about your online activities to provide you with advertising about products and services tailored to your interests. Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.

You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites. This data collection takes place both on our websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

Our Online Channels are not designed to respond to “do not track” signals received from browsers.

IV. Information We Share

We do not sell or otherwise share personal information about you except as described in this Privacy Policy. We may share your personal information with (1) our affiliates and (2) our service providers who perform services on our behalf, such as order fulfillment and data analytics. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We also may disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

V. Rights and Choices

We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, limit the communications you receive from us, or submit a request, please contact us as specified in the How to Contact Us section of this Privacy Policy. You can also unsubscribe from our mailing lists by following the “Unsubscribe” link in our emails.

Subject to applicable law, you may (1) have the right to access the personal information we maintain about you; (2) request that we rectify personal information about you that is inaccurate; and (3) request that we delete personal information about you. Where you have consented to the processing of your personal information, you may have the right to withdraw your prior consent at any time. To exercise these rights, please contact us as indicated in the How to Contact Us section of this Privacy Policy. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.

VI. Other Online Services and Third-Party Features

The Online Channels may contain links to third-party websites, products, and services for your convenience and information, including social media sites such as Facebook, Twitter, Instagram, Pinterest, YouTube, and LinkedIn, etc. These third-party websites, products and services may operate independently from us. Information collected by these third-party websites is governed by their privacy practices and is not subject to this Privacy Policy. We are not responsible for how these third-party services collect, use, disclose, distribute, or maintain your personal information. We encourage you to learn about the privacy practices of those third parties prior to providing them with any information or taking advantage of an offer or promotion.

VII. How We Protect Personal Information

We maintain safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

VIII. Children’s Personal Information

The Online Channels are designed for a general audience and are not directed to children. We do not knowingly collect or solicit personal information from children under the age of 13 (or other relevant age, as applicable pursuant to relevant law) through the Online Channels. If we become aware that we have collected personal information from a child under such age, we will promptly delete the information from our records. If you believe that a child under such age may have provided us with personal information, please contact us as specified in the How to Contact Us section of this Privacy Policy.

IX. Data Transfers

We may transfer the personal information we obtain about you to countries other than the country in which the information originally was collected, such as the United States. Those countries may have different data protection laws than the country in which you initially provided the information. To the extent required by applicable law, when we transfer your personal information to the United States or other countries, we take measures to protect that information as described in this Privacy Policy.

If you are located in the European Economic Area (“EEA”), United Kingdom (“UK”) or Switzerland, with respect to transfers of personal information to the U.S., Genius Creative Adventures is certified under the EU-U.S. and Swiss-U.S. Privacy Shield frameworks developed by the U.S. Department of Commerce, and the European Commission and Swiss Federal Data Protection and Information Commissioner, respectively, regarding the transfer of personal information from the EEA, UK and Switzerland to the U.S.

X. How To Contact Us

If you have any questions regarding this Privacy Policy or our privacy practices, you may email us at privacy@geniuscreativeadventures.com with “PRIVACY POLICY” in the subject line or write to:

Genius Creative Adventures, Customer Care Department
P.O. Box 69
Lake George, CO 80827

XI. Updates To Our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a notice on our websites and mobile apps to notify you of significant changes to our Privacy Policy and indicate at the top of the notice when it was most recently updated.

XII. California Consumer Privacy Statement

This California Consumer Privacy Statement supplements the Privacy Policy and applies solely to California consumers. This Statement does not apply to Genius Creative Adventures personnel or job applicants.

This California Consumer Privacy Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1. Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as device identifier, telephone number, customer number, cookies, beacons, pixel tags, mobile ad identifiers and similar technology), online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as gender, age, race, and veteran and disability status
• Commercial Information: commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Biometric Information
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an advertisement or the Online Channels
• Geolocation Data
• Sensory Information: audio, electronic, visual, thermal, olfactory and similar information
• Employment Information: professional or employment-related information
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of personal information listed above for the purposes described in our Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

Purposes	Categories of Personal Information
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Debugging to identify and repair errors that impair existing intended functionality	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Undertaking internal research for technological development and demonstration	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences

2. Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in Section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have disclosed for a business purpose.

a. Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Categories of Sources of Data Collection	Categories of Personal Information
Directly from you, for example, in stores or at events	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
From your devices, such as through your use of the Online Channels	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Your friends, through their use of the Online Channels, such as by providing product information to you or completing a purchase sent directly to you	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Our affiliates	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Vendors who provide services on our behalf	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Third-party marketplaces	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Third-party marketplaces	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Our joint marketing partners	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Social networks	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Online advertising services	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Government entities	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Consumer data resellers	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences

b. Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties	Categories of Personal Information
Our affiliates	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Vendors who provide services on our behalf	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Professional services organizations, such as auditors and law firms	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Our joint marketing partners	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Online advertising services	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Government entities	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Our business partners	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Internet service providers	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Data analytics providers	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Operating systems and platforms	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Social networks	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences
Consumer data resellers	Identifiers Additional Data Subject to Cal. Civ. Code § 1798.80 Protected Classifications Commercial Information Biometric Information Online Activity Geolocation Data Sensory Information Employment Information Inferences

We do not sell personal information and have not sold personal information during the 12-month period prior to the effective date of this Privacy Policy. We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.

c. Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties for a business purpose the following categories of personal information:

• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Biometric Information
• Online Activity
• Geolocation Data
• Sensory Information
• Employment Information
• Inferences

3. California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information

Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request. To submit an access or deletion request, email privacy@geniuscreativeadventures.com or call us.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign in to your account or requiring you to respond to an email from the email address associated with your account. Whether or not you have an account with us, we may also ask you to provide details regarding your most recent transaction with us. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access or deletion request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact us privacy@geniuscreativeadventures.com or call us to request this Statement in an alternative format.

EU/SWISS-U.S. PRIVACY SHIELD: CONSUMER PRIVACY POLICY

Privacy Policy

(Last Updated June 23, 2020)

The Genius Creative Adventures, LLC, Lakeshore Castle, LLC, and its subsidiaries and (collectively, “Genius Creative Adventures”) respect your concerns about privacy. Genius Creative Adventures participates in the EU-U.S. and Swiss-U.S. Privacy Shield (collectively, “Privacy Shield”) frameworks issued by the U.S. Department of Commerce. Genius Creative Adventures commits to comply with the Privacy Shield Principles with respect to Consumer Personal Data the company receives from the EU, UK and Switzerland in reliance on the Privacy Shield. This Policy describes how Genius Creative Adventures implements the Privacy Shield Principles for Consumer Personal Data.

For purposes of this Policy:

“Consumer” means any natural person who is located in the EU, UK or Switzerland, but excludes any individual acting in his or her capacity as an Worker.

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“EU” means the European Union and Iceland, Liechtenstein and Norway.

“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Genius Creative Adventures in the U.S. from the EU, UK or Switzerland, and (iii) recorded in any form.

“Privacy Shield Principles” means the Principles and Supplemental Principles of the EU-U.S. and Swiss-U.S. Privacy Shield frameworks.

“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.

“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (including trade union-related views or activities), sex life (including personal sexuality), information on social security measures, 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 (including administrative proceedings and criminal sanctions).

“UK” means the United Kingdom.

“Worker” means any current, former or prospective employee, intern or temporary worker of Genius Creative Adventures, or any related individual whose Personal Data Genius Creative Adventures processes in connection with an employment relationship, who is located in the EU, UK or Switzerland.

Genius Creative Adventures’ Privacy Shield certification, along with additional information about the Privacy Shield, can be found at https://www.privacyshield.gov/. For more information about Genius Creative Adventures’ processing of Consumer Personal Data, please visit Genius Creative Adventures’ Privacy Policy.

Types of Personal Data Genius Creative Adventures Collects

• contact information (such as name, postal address, telephone number and email address);
• payment information (such as such billing address and payment card details, including card number, expiration date and security code);
• account information, such as online password and other log-in details used to access Genius Creative Adventures products and services;
• location data (such as data derived from Consumers’ IP address, country and/or ZIP code), and, with the Consumer’s consent, the precise geolocation of the Consumer’s mobile device;
• social media handles, content and other data posted on our official social media pages;
• information we obtain from third-party social media services (e.g., Facebook) or payment services (e.g., PayPal) if a Consumer chooses to link to, create or log into the Consumer’s Genius Creative Adventures account through these services;
• data collected automatically through Genius Creative Adventures’ website (such as IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on Genius Creative Adventures’ website and dates and times of activity);
• contact information Consumers provide about friends or other people Consumers would like us to contact; and
• other personal information found in content that Consumers provide, such as through our “Contact Us” feature, questionnaires or customer support tools available on Genius Creative Adventures’ website, mobile sites and mobile apps and services (collectively, the “Online Services”).

Genius Creative Adventures may use the Consumer Personal Data it collects to:

• process and fulfill orders and purchases and keep Consumers informed about the status of their orders;
• establish and manage Consumers’ accounts;
• identify and authenticate Consumers so they may order our products and access and use the Online Services;
• provide customer and technical support and respond to inquiries;
• communicate with Consumers regarding news updates, notices, special promotional offers, advertisements and marketing materials, Genius Creative Adventures products and services, or other information that may be of interest;
• communicate about, and administer participation in, special events, programs, promotions, offers, surveys, focus groups and market research;
• notify Consumers about product safety and recall information, such as reporting an adverse event or communicating a product recall;
• increase and maintain the safety and security of Genius Creative Adventures products and the Online Services and prevent misuse;
• operate, administer, evaluate, develop, manage and improve our business and the Online Services (including operating, administering, analyzing and improving our products, services and Online Services; developing new products and services; performing analytics (including market research, trend analysis, financial analysis, and anonymization and aggregation of personal information); managing and evaluating the effectiveness of our communications; and performing accounting, auditing, billing reconciliation and collection activities and other internal functions);
• protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
• comply with and enforce applicable legal requirements and relevant Genius Creative Adventures and industry standards and policies.

The Genius Creative Adventures also may obtain and use Consumer Personal Data in other ways for which Genius Creative Adventures provides specific notice at the time of collection.

The Genius Creative Adventures’ privacy practices regarding the processing of Consumer Personal Data comply with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.

Notice

The Genius Creative Adventures provides information in this Policy and the company’s Privacy Policy about its Consumer Personal Data practices, including the types of Personal Data Genius Creative Adventures collects, the types of third parties to which Genius Creative Adventures discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data, and how to contact Genius Creative Adventures about its practices concerning Personal Data.

Relevant information also may be found in notices pertaining to specific data processing activities.

Choice

The Genius Creative Adventures generally offers Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the Privacy Shield Principles, Genius Creative Adventures obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact Genius Creative Adventures as indicated below regarding the company’s use or disclosure of their Personal Data. Unless Genius Creative Adventures offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy.

The Genius Creative Adventures shares Consumer Personal Data among Genius Creative Adventures-related entities. Genius Creative Adventures may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. Genius Creative Adventures also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

Accountability for Onward Transfer of Personal Data

This Policy and the Genius Creative Adventures’ Privacy Policy describe Genius Creative Adventures’ sharing of Consumer Personal Data.

Except as permitted or required by applicable law, Genius Creative Adventures provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Genius Creative Adventures requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (iii) notify Genius Creative Adventures and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.

With respect to transfers of Consumer Personal Data to third-party Processors, Genius Creative Adventures (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Genius Creative Adventures’ obligations under the Privacy Shield Principles, (v) requires the Processor to notify Genius Creative Adventures if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Genius Creative Adventures remains liable under the Privacy Shield Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Genius Creative Adventures proves that it is not responsible for the event giving rise to the damage.

Security

The Genius Creative Adventures takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

Data Integrity and Purpose Limitation

The Genius Creative Adventures limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. Genius Creative Adventures does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes, Genius Creative Adventures takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, Genius Creative Adventures relies on its Consumers to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers may contact Genius Creative Adventures as indicated below to request that Genius Creative Adventures update or correct relevant Personal Data.

Subject to applicable law, Genius Creative Adventures retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer 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 the Consumer.

Access

Consumers generally have the right to access their Personal Data. Accordingly, where appropriate, Genius Creative Adventures provides Consumers with reasonable access to the Personal Data Genius Creative Adventures maintains about them. Genius Creative Adventures also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. Genius Creative Adventures may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’s privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting Genius Creative Adventures as indicated below.

Recourse, Enforcement and Liability

Genius Creative Adventures has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. Genius Creative Adventures conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Genius Creative Adventures makes about its Privacy Shield privacy practices are true and that Genius Creative Adventures’ privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

Consumers may file a complaint concerning Genius Creative Adventures’s processing of their Personal Data. Genius Creative Adventures will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact Genius Creative Adventures as specified below about complaints regarding Genius Creative Adventures’ Consumer Personal Data practices.

If a Consumer’s complaint cannot be resolved through Genius Creative Adventures’ internal processes, Genius Creative Adventures will cooperate with JAMS pursuant to the JAMS Privacy Shield Program, which is described on the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the DPAs, ICO or Swiss Federal Data Protection and Information Commissioner, as appropriate, may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over Genius Creative Adventures. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Genius Creative Adventures’ compliance with the Privacy Shield Principles.

How to Contact Genius Creative Adventures

To contact Genius Creative Adventures with questions or concerns about this Policy or Genius Creative Adventures’ Consumer Personal Data practices:

Write to:

Genius Creative Adventures
P.O. Box 729
Lake George, Colorado 80827 USA

E-mail:

privacy@geniuscreativeadventures.com (include “PRIVACY SHIELD” in the subject line).