Thank you for choosing to be a part of our community at Luxury Frontiers LLC (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at aaron.gjellstad@luxury-frontiers.com.

When you visit our website, www.luxury-frontiers.com, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Site.

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This privacy policy applies to all information collected through our website, and/or any related services, marketing, or events (we refer to them collectively in this privacy policy as the “Sites”).

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

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1. WHAT INFORMATION DO WE COLLECT?

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Personal Information You Disclose to Us

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We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our services, when participating in activities on the Sites, or otherwise contacting us.

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The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make, and the services and features you use. The personal information we collect can include your first and last name, email address, phone number, and other similar contact data.

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All personal information that you provide us must be true, complete, and accurate, and we appreciate you notifying us of any changes to such personal information.

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Information Automatically Collected

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We automatically collect certain information when you visit, use, or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites, and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.

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Like many businesses, we also collect information through cookies and similar technologies.

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Information Collected From Other Sources

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We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information, marketing leads, and search results and links, including paid listings (such as sponsored links).

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2. HOW DO WE USE YOUR INFORMATION?

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We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”) in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.

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We use the information we collect or receive:

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• To send you marketing and promotional communications for Business Purposes. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time. You may do so by following any instructions included in the marketing communication or by contacting us using the contact information below (also see the “What Are Your Privacy Rights” section below).

• Deliver targeted advertising to you for our Business Purposes. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our marketing campaigns, and to evaluate and improve our Sites, services, marketing, and your experience.

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3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

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We only share and disclose your information in the following situations:

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• Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

• Vital Interests and Legal Rights. We may disclose your information where we believe it necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

• Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors, or agents who perform services for us on our behalf and require such access to such information to do that work. Examples include: data analysis, email delivery, hosting services, and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. Unless described in this Policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Business Partners. We may share your information with our business partners to offer you certain services or promotional material.

• With Your Consent. We may disclose your personal information for any other purpose with your consent.

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4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

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We may use cookies and other similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy below.

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5. HOW LONG DO WE KEEP YOUR INFORMATION?

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We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

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When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

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6. HOW DO WE KEEP YOUR INFORMATION SAFE?

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We have implemented appropriate organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

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7. DO WE COLLECT INFORMATION FROM MINORS?

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We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such a minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under 18, please contact us at aaron.gjellstad@luxury-frontiers.com.

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8. WHAT ARE YOUR PRIVACY RIGHTS?

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In some regions, such as the European Economic Area, you have certain rights under applicable data protection laws. These may include the right to (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details below. We will consider and act upon any request in accordance with applicable data protection laws.

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If you are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note, however, than this will not affect the lawfulness of the processing before its withdrawal.

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If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Cookies and other similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To opt-out of internet-based advertising you may encounter on our Sites, visit http://www.aboutads.info/choices/.

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9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

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California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

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10. DO WE MAKE UPDATES TO THIS POLICY?

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We may update this privacy policy from time to time to stay compliant with relevant laws. If we make material changes to this privacy policy, we may notify you either by promptly posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

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11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

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If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Aaron Gjellstad, by email at aaron.gjellstad@luxury-frontiers.com, by phone at +1 628 218 7355, or by post to:

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Luxury Frontiers LLC
Aaron Gjellstad
101 Larkspur Landing Circle
Suites 228
Larkspur, CA 94939
USA

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If you have any further questions or comments about us or our policies, email us at jamierose.briones@luxury-frontiers.com or by post to:

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Luxury Frontiers LLC
101 Larkspur Landing Circle
Suites 228
Larkspur, CA 94939
USA

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