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FRANKIE4 Privacy Policy

Last revised: December 2025

1  Introduction

Overview

Frankie4 Footwear US Limited (“Company” “we” or “us”) operates the following website: us.frankie4.com (the “Website”). Frankie4Footwear US Limited and its parent company, Frankie4 Holdings Pty Ltd, and affiliates FrankieB Pty Ltd, collectively trading as Frankie4, are committed to respecting your right to privacy and protecting your personal data. This privacy notice aims to inform you about how we collect, use, disclose, store, secure and dispose personal data about you when you:

  • interact or use our Website including registering with us on the Website and
  • if you purchase any of our products through the Website (collectively the “Services”).

2 Privacy Notice

Scope

This policy covers any Services being provided by Company and interactions you may have with our Website.

Privacy Principles we follow

Company will ensure that all personal data that it holds will be:

  • processed lawfully, fairly and in a transparent manner;
  • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  • adequate, relevant and limited to what is necessary;
  • accurate and kept up to date;
  • kept in a form which permits identification of data subjects for no longer than is necessary;
  • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

Notice at Collection for California Residents

We collect the categories of personal data identified in Section 2.1 (Types of Information We Collect), below, for the purposes identified in Section 2.3 (How we use your information), below, and retain personal data for the period described in Section 2.7 (How we dispose of your information), below. We may “sell” or “share” your personal data, as the California law defines those terms. We do not collect or process sensitive personal data for the purpose of inferring characteristics about you. To the extent you provide the Company with personal data about other California residents, you are responsible for providing this notice to them.

 

If you provide us with personal data about another individual, for example, through our Refer a Friend Program, you must obtain that individual’s consent and provide this Privacy Notice to them.

2.1 Types of personal data we collect

When you visit our Website, we may collect personal data from you for legitimate business purposes. We will use this data in connection with your visit to our Website and to fulfill any business interaction that you may enter into with us. You may, for example, provide us with your personal data when you:

  • purchase items listed for sale on our Website;
  • create an account on our Website;
  • communicate with us through the "Online Chat" link on our Website; and
  • apply for a job or internship.

We may also automatically collect data about you, such as technical information about your computer or internet browser. Data may also be collected about you indirectly through monitoring activities which will be conducted by or on our behalf in accordance with relevant legislation or regulatory requirements (for example, monitoring e-mails that we receive from you or recording telephone calls when you contact us).

If you participate in our Refer a Friend Program, we may receive your personal data from another customer.

The personal data that we collect from you may include:

- Identifiers, including name, mailing address, email address, and other contact information;
- Commercial information in the form of records of your purchases from us;
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an advertisement;
- Communications, including the content of your emails and chat messages with us, as well as information about those communications, for example, date and time sent;
- Location data in the form of geographic region based on IP address;
- Photos, videos, and recordings, for example, if you leave reviews with photos or videos of you wearing our shoes or you leave a voicemail;
- Professional information if you sign up for one of our discounts for health professionals or educators; and
Inferences, for example, a preference for a certain shoe style based on your record of purchases.

We will process your personal data for the purposes listed above on the basis of one or more of the following:

- The processing is necessary for the performance of a contract or for entering into a contract with you. Please note that where this is the case, we may not be able to perform or enter into a contract with you unless you provide your personal data;

- The processing is necessary to comply with a legal obligation;

- You have given your consent (where we rely on this legal basis, we will always seek to obtain your consent separately as and when necessary); and

- Our legitimate interests, including:

o Providing you with the goods or services requested
o Improving and personalizing Services
o Marketing activities
o Market research

2.2 How we collect your personal data

Legitimate Business Purposes for the collection of personal data:

  • Providing you with the goods or services requested
  • Improving and personalizing Services
  • Marketing activities
  • Market research

We collect personal data in different ways. Directly from you; for example, when you:

  • Make a purchase on our Website.
  • Create a personalized account or log in to such account.
  • Track an order online.
  • Sign up to receive promotional emails or text messages (including offers and sales alerts).
  • Use any ratings & reviews or related services and features on our Website.
  • Submit a request to our Customer Service team.
  • Use the Website's chat or search features.
  • Visit and navigate Company's Website on any device.
  • Enable location-based features on our Website.
  • Interact with Company's social media pages, including but not limited to Facebook, Twitter, TikTok Pinterest, YouTube and Instagram.

We may also combine personal data we collect about you from the different devices you use to access our Platforms.

2.2.1 Collection of personal data by automated means

Personal data that is passively collected:

Cookies and similar technologies:

  • When you visit the Website, we may use “cookies” which are small files stored as text on your computer or device. In some regions or countries, we are not permitted to send cookies to the browser of a user without the prior consent of the affected user. In this case, we will seek such consent (for more information, see Section 5. EU and EEA Residents). The remainder of this section assumes that either the use of cookies is not restricted by applicable law, or if it is restricted that the individual has explicitly consented to the use of the cookies.
  • These “cookies” and other similar technologies like pixels, web beacons (also known as “clear GIFs”) and local storage may be used to collect information about how you use the Services and provide features to you.
  • If a visitor does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies. Please note that if you use your browser settings to modify or block all cookies, you may not be able to access parts of the Services and your user experience may be severely degraded. We may share non-Personal data obtained via cookies with our advertisers and affiliates.
  • A visitor may update their cookie preferences through the ‘Manage Cookie Preferences’ link in the footer of the Website. This link allows visitors to opt out of Analytics or Performance Cookies, Targeting or Advertising Cookies, Preference Cookies.
  • Information provided by these cookies are essential to help us provide the Services in a manner that is adapted to each user’s specific needs. We believe that such means are fair, lawful, and proportional to the legitimate interest and needs of our business, and that our methodology fairly addresses each user’s legitimate rights and expectations in view of the context and purpose for the collection and use of the information collected.

Mobile Device Unique Identifier

  • When you use a mobile device to connect to our Website via a service provider that uniquely identifies your mobile device, we may use this unique identifier to offer you extended services and/or functionality. Certain Services may require the collection of your mobile phone number. We may associate that mobile phone number with the mobile device unique identifier.

Log file information:

  • Log file information may be automatically reported by your browser each time you make a request to access (i.e., visit) your account on the Website. It can also be provided when the content of the Services is downloaded to your browser or device.
  • When you use the Services, our servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Services.

Strictly Necessary Cookies:

  • Necessary cookies are used for the purpose of authentication and providing data security. These cookies are necessary for our Website to work and enable us to distinguish users and enable you to use its services and features. Disabling these cookies will encumber our Website’s performance and may make these services and features unavailable.

Functional Cookies:

  • These cookies enable the Website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.

Targeting or Advertising Cookies

  • These cookies are used to deliver content that is more relevant to you and your interests. They may be used to deliver targeted advertising or to limit the number of times that you see an advertisement. They also can help us measure the effectiveness of advertising campaigns on the Website. These cookies may be used to remember websites that you have visited. As of February 2025 Klaviyo will use a first-party cookie to re-issue the Klaviyo cookie. 

Analytics or Performance Cookies:

  • These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the Website. If you do not allow these cookies we will not know when you have visited our Website and will not be able to monitor its performance.

2.3 How we use your personal data

The following are the examples of how we may use your personal data for the legitimate interest of our business which include:

  • To Understand Your Interests. For example, we may use your personal data to better understand what products interest you based on information we collect about you and your household.
  • To Communicate with You. We may communicate with you about your account or our relationship. We may also contact you about this Privacy Notice or the Services.
  • Our Products and Services. We may use your personal data to enhance our Website and Services to serve you better.
  • To Respond to Your Requests or Questions. This may include responding to your customer feedback.
  • For Security Purposes. This could include protecting our company and our customers. It may also include protecting our Website.
  • For Marketing Purposes. We may provide you with information about new products and special offers. We may use your information to serve you ads about products and offers. We may tell you about new features or updates.
  • To Support Our Products and Services. This could include fulfilling your requests for products or Services. It could also include processing purchases or return transactions.
  • Law or regulatory obligations. Certain laws and regulations require us to maintain and disclose collected personal data.

If we use your personal data for any other purposes, we will provide you with a separate notice.

2.4 How we disclose your personal data

We operate globally and from time to time, we may also need to transfer your personal data to third parties in other countries where we do business, have affiliates, or have a service provider. Such countries may not have the same data protection laws as the USA or European Union or the country in which you reside.

When transferring your personal data, we will take all appropriate steps to provide an adequate level of protection for your personal data in accordance with relevant legislation. These steps may include exercising audit and inspection activities in respect of the actions of those third parties in connection with the use of your personal data.

At any time you may opt-out of us sharing your personal information, such as Cookies or similar technologies. To submit this request, follow the prompts here: https://us.frankie4.com/pages/do-not-sell-or-share-my-personal-information

If at any time you wish that we cease any activity that affects you, please contact us as indicated in the “How to Contact Us” Section below. We may disclose/share your personal data in the following ways:

  • With Our affiliates. Frankie4 Holdings Pty Ltd, FrankieB Pty Ltd, collectively trading as Frankie4.
  • On our Website. For example, we may display information you post on our verified buyer reviews feature.
  • With Our Business Partners. We may disclose your personal data with persons or organizations involved in providing your product or service, or components of your product or service, including independent contractors engaged by us. For example, we disclose the contents of your messages to us through our Website chatbot and queries in our Website search function to service providers that support those features. We may also disclose your personal data to businesses who co-sponsor a promotion or giveaway with us when you enter into such promotion or giveaway.
  • With Our Service Providers. We may disclose your personal data with third parties who perform services on our behalf. For example, this may include vendors and payment processors. It may also include companies that send emails on our behalf. Please note that we utilize a third party payment processor to assist with all payments made on our Website. Should you have a question regarding the payment processor’s privacy policy, please check their website.
  • Corporate transactions. We may disclose your personal data to persons or organizations interested in purchasing part or all of our business.
  • Government, courts, and Law enforcement. We will access, preserve, and disclose any personal data about you, without your consent, to government or law enforcement officials or private parties as we in good faith believe necessary or appropriate to respond to claims and legal process (including, but not limited to, subpoenas), to comply with applicable laws, to protect the property and rights of Company, you or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to pose a risk of being, or is illegal, unethical or legally actionable. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
  • We may also access, preserve and disclose personal data when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Personal data we receive about you may be accessed, processed and retained for anextended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

2.5 How we store your personal data

By registering for and using the Services you consent to the transfer of personal data to anywhere in the U.S. where the Services or its Service Providers maintain facilities and the use and disclosure of personal data about you as described in this Privacy Notice. In order to perform one or more of our functions or activities, we may transfer your personal data to service providers, including warehousing and logistics providers outside the US. These countries include, but are not limited to, Australia, Belgium, Germany, Netherlands and New Zealand.

Although we implement reasonable administrative, physical and electronic security measures designed to protect your Personal data from unauthorized access, we cannot ensure the security of any information you transmit to or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically storedPersonal data. To the extent the law of your jurisdiction allows for notification of a breach via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

  • the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

2.6 How we protect your personal data

While no data transmission over the internet is 100% secure, we are committed to protecting the information we receive from you. We take appropriate security measures to protect your personal data against unauthorized access to or unauthorized alteration, disclosure or destruction of data. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of personal data, we maintain appropriate physical, electronic, and managerial procedures to safeguard and secure the information and data stored on our system.

While no computer system is completely secure; we believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved. The Website may contain links to other websites that we do not own or control. The Privacy Notice does not apply to these websites and we are not responsible for the privacy practices of such websites or other services operated by such websites. Once you leave the Website via such a link, we recommend your review the privacy policy applicable to such third-party websites to learn how they use and disclose your personal data.

Our staff are trained in how to keep your personal data safe and secure. We use secure systems and buildings to hold your personal data. We aim to only keep your personal data for as long as we need it.

We will maintain data security by protecting the confidentiality, integrity and availability of the Personal data, defined as follows:

- Confidentiality: only people who are authorized to use the data can access them;

- Integrity: Personal data should be accurate and suitable for the purpose for which they are processed;

- Availability: authorized users should be able to access the data if they need it for authorized purposes.

2.7 How we dispose your personal data

Our goal is to retain your personal data “no longer than necessary for the purposes that we collect and use data”; Upon the expiry of our data retention periods or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise securely disposed of as follows:

  • Personal data stored electronically (including any and all backups thereof) shall be deleted.
  • Special category personal data stored electronically (including any and all backups thereof) shall be deleted.
  • Personal data stored in hardcopy form shall be shredded if not required
  • Special category personal data stored in hardcopy form shall be shredded straight away if no longer required.

2.8 Payment information

You may also make payments using the third-party payment services provider, such as Stripe or Shopify, made available through the Websites. In connection with making payments, you may be required to provide additional information to facilitate the transaction, such as your bank account or credit card information. Company does not store or use this payment information in any way other than to relay the information to the third-party payment services provider to facilitate the transfer of funds. After payment, Company does not have access to your bank account or credit card information. Company disclaims any liability for any loss or compromise of payment information. The third-party payment services provider’s use of such information shall be governed by its applicable terms of services and/or privacy policy.

2.9 Children’s Privacy

Company does not knowingly collect or solicit any personal data from anyone under the age of 18 or knowingly allow such persons to register for the Services. The Services and their content are not directed at children under the age of 18. In the event that we learn that we have collected personal data from a child under age 18 without parental consent, we will delete that data as quickly as possible. If you believe that we might have any personal data from or about a child under 18, please contact Company at info@frankie4.com.

If you are a California resident under the age of 16, we do not knowingly share any personal data without parental consent. Contact Company at info@frankie4.comfor assistance or any related questions.

2.10 Your choices about your information

Text messaging

You may opt-out of receiving text messages by replying “STOP” to any text message received.

Emails

  • In all promotional emails, you will be given the opportunity to opt-out of receiving such messages in the future by clicking on the link at the bottom of the email that says “unsubscribe.”
  • Please note, we reserve the right to send you Services-related communications (e.g., account verification, payment confirmations, technical and security notices) for which you may not opt out.

Cookies

If a visitor does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies. Please see more information about cookies options in Section 2.2.1 above.

Mobile device unique identifier

Unless you choose to opt out, we may also disclose your mobile phone number with certain select third parties. You can opt out by changing the privacy settings on your profiles/devices. Please see the region-specific sections for more information on opting out.

2.11 International Data Transfers

Personal data you submit on the Website or through the Services may be sent to the other countries, on our service providers’ cloud servers. We will always protect your personal data in accordance with this Privacy Notice wherever it is processed. While our headquarters are in Australia, the Website is based in the US and by accessing our Website, you grant us expressed consent to transfer your personal data to US servers. If you do not wish for us to transfer your personal data to the US, please contact us using the information in the “How to Contact Us” section below.

This section sets out the privacy principles we follow with respect to transfers of personal data from the European Economic Area (EEA) to the United States, including personal data we receive from individuals residing in the EEA who visits our Website and/or who may use our Services or otherwise interact with us.

Please note that for users located in the EEA, the term personal data used in this privacy is equivalent to the term “personal data” under applicable European data protection laws.

3 U.S. Residents

This Section provides additional information for individuals who reside in U.S. states with comprehensive data protection laws (collectively, “Applicable State Privacy Laws”), to the extent that our collection and handling of personal data is subject to these laws. These include residents of California, Texas, and other states with similar laws and regulations, as enacted or amended from time-to-time.

3.1 Additional information about uses of personal data

We do not make decisions solely based on automated processing with legal or similarly significant effects, and we also do not infer characteristics from sensitive personal data.

We may aggregate and/or deidentify information, use it internally, and disclose to third parties. Neither Aggregated Information nor Deidentified Information (defined below) is personal data.
- “Aggregated Information” refers to information about a group of individuals from which the individually identifiable information has been removed. An example of Aggregated Information would be the statistic that 20 people used our website’s contact form on a given day.

- “Deidentified Information” means information subjected to reasonable measures to ensure that the deidentified information cannot be associated with the individual. An example of Deidentified Information would be the data point that an unidentified visitor first entered the Site through our main web page. We maintain Deidentified Information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information just to determine whether our deidentification processes function correctly.

3.2 Additional information about disclosures of personal data

We may disclose your personal data to third parties for the following “business purposes” as that term is defined under the California Consumer Privacy Act and as a supplement to the disclosure described in Section 2.4 (How we disclose your information), above:
- Service Providers: We may disclose any of the categories of personal data listed above to service providers for the business purpose of performing services on our behalf, as well as (a) helping to ensure security and integrity, (b) debugging, (c) short-term transient use, (d) internal research, and (e) activities to maintain or improve the quality or safety of a service or device.
- Professional Advisors and Related Third Parties: We may disclose any of the categories of personal data listed above to the professional services providers listed in Section 6 (How We Disclose Personal data), above, for the business purpose of auditing compliance with policies and applicable laws in addition to performing services on the Company’s behalf.
- Affiliated Companies: We may disclose any of the categories of personal data listed above to other companies within the Frankie4 corporate group for the business purposes of: (a) auditing compliance with policies and applicable laws, (b) helping to ensure security and integrity, (c) debugging, (d) short-term transient use, (e) internal research, and (f) activities to maintain or improve the quality or safety of a service or device.

3.3 Sales and targeted advertising

We do not “sell” your personal data as most people would understand that term, meaning that we do not disclose your personal data to any third party in exchange for a monetary payment. However, as is common practice among businesses operating online, we may allow third parties to receive information about you for purposes of analyzing and optimizing our services, to personalize your online experience by providing advertisements that are more relevant to you, and for statistical research and analytics. These activities may be defined as “sale” of personal data or use of personal data for targeted advertising (or “sharing” for cross-context behavioral advertising).

In the last 12 months, we have disclosed identifiers, commercial information, location data in the geographic region based on IP address, professional information, communications, and inferences to our marketing partners (marketing and analytics partners, advertisers, and social media platforms). We disclose this personal data in order to deliver marketing messages, tailor advertising on the Website and in other interactions that you have with us while online, and to and help us understand the effectiveness of those marketing and advertising efforts.

We have no actual knowledge that we have sold or “shared” the personal data of children under 16, in the last 12 months and we have no intention to do so.

We understand that these forms of disclosure and targeted advertising aren’t for everybody, and you have options. You can opt-out of this type of activity using the methods described further below.

3.4 Your privacy rights

Subject to any applicable limitations and exceptions, you have the following rights under Applicable State Privacy Laws:
- Right to Access/to Know: You have the right to request information about whether we process your personal data, to access that information, and certain details about how we use it. If you are a resident of California, you have the right to information about whether we process your personal data, and our collection, use, and disclosure of categories of your personal data. In addition, in lieu of a right to access, you have the right to submit a verifiable request to know specific pieces of your personal data obtained from or about you.
- Right to Know Disclosures: Residents of certain states have the right to obtain, at the Company’s option, a list of specific third parties to which we have disclosed either your personal data, or any personal data.
- Right to Delete: You have the right to submit a request to delete personal data that we have collected from or about you.
- Right to Correct: You have the right to submit a request to correct inaccurate personal data about you, taking into account the nature of the personal data and the purposes of processing the personal data.
- Data Portability: You have the right to request that we provide you, or send to a third party, a copy of your personal data in electronic form that you provided to us.
- Non-Discrimination: You have the right not to be discriminated against for exercising any of your privacy rights under Applicable State Privacy Laws. To be clear, we do not tolerate unlawful discrimination of any kind.
- Right to Opt Out of Sale/Targeted Advertising: You have the right to opt out of the sale of your personal data and the disclosure of your personal data for targeted advertising (or “sharing” for cross-context behavioral advertising) You may also implement a browser setting or extension to communicate your selling and sharing preferences automatically to the websites you visit.

3.5 How to exercise your privacy rights

We will respond to requests for data portability, to know, and to access, correct, or delete your personal data in accordance with Applicable State Privacy Laws, if we can verify the identity of the requestor. You can exercise these rights in the following ways:
- Call (844) 364-4544
- Submit a request via this link
- Email info@frankie4.com
You may also have the right to appeal any decision we make in response to a request to exercise privacy rights, by using the methods listed above. We will inform you of any action taken in response to an appeal, along with a written explanation of the reasons for our decision(s), in accordance with Applicable State Privacy Laws.

3.6 Notice of right to opt out of sale/targeted advertising

To opt out of the sale of your personal data or its use for targeted advertising (“sharing”), please use this link.

You can update your cookie preferences at any time via this link.

In addition, you may use the Global Privacy Control (GPC) to opt out of cookies that sell personal data or use it for targeted advertising.
To enable the GPC:
(1) Go to Global Privacy Control — Take Control Of Your Privacy.
(2) Click on “Get Started”.
(3) Click on “View All Downloads”.
(4) Under “Browsers + Extensions”, select a participating company and click “Download”.
(5) Follow the instructions provided by the selected company for installing its browser.

If you have enabled the GPC, we will not be able to track your activity through the web. This may affect our ability to personalize ads according to your preferences. However, if you visit our Website from a different device or from a different browser on the same device, you will need to opt-out of sale/sharing using the interactive form available through the link provided above or use an opt-out preference signal for that browser and/or device.

3.7 How we will verify your request

If you submit a request for data portability, to know, or to access, correct, or delete your personal data, we verify your identity by matching personal data that you provide us against personal data we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal data), the more items of personal data we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.

3.8 Authorized agents

You may designate an authorized agent to exercise your rights. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your identity.

3.9 California's "shine the light" law

California consumers who use the services may request that we provide certain information regarding our disclosure of your personal data to third parties for their direct marketing purposes. You can make such a request by e-mail to info@frankie4.com.

3.10 Notice of financial incentives / bona fide loyalty program

We make available to customers rewards programs and other sweepstakes, contest, or and similar promotional offerings (each a “Program”), which include certain offers, rewards, discounts, services, perks and promotions (“Rewards and Offers”).

We collect, disclose, and retain personal data about participating customers as part of these Programs, which may be considered financial incentives under applicable laws, including the California Consumer Privacy Act (“CCPA”). We provide these Rewards and Offers in order understand and improve customer satisfaction and experiences and foster positive customer relationships. The value of your personal data to us is related to the costs and expenses associated with making the Rewards and Offers available to Program participants (including IT, administration, direct costs, third party costs, and service development costs).

Your personal data is collected and retained, and may be disclosed to third parties, as described in our Privacy Notice including in order (i) to administer the Program, (ii) for research and analytics purposes, (iii) to improve our products and services, (iv) to better reach you with more relevant, targeted ads and offers in-store, online, and on third party sites and platforms, and (v) to send you news, updates and offers by email, postal mail and text message (in accordance with your communications preferences).

You may withdraw from participating in a Program at any time by contacting us using the designated method set forth in the applicable Program terms. Please note that if you withdraw from a Program (or you submit a request to delete your Program data), your participation in that Program will be terminated, which means, generally, that you will no longer be eligible to earn, use, access or redeem any Program Rewards and Offers, subject to the applicable Program terms. This does not apply with respect to deleting optional profile information, but it does apply with respect to deleting identifying information or information about your participation in the Program, e.g., number of qualifying purchases.

Refer a Friend Program. Customers may join our Refer a Friend Program, as described in more detail here, to earn rewards for referrals. To join the Refer a Friend Program, you must use the official referrer system (if you are a referrer) or click on the unique referral link and complete a purchase attributable to the referral link (if you are a recipient of a referral). Participants provide personal data in the form of electronic tracking information and order information.

Health Professionals Privilege Program and Educators Privilege Program. Eligible individuals may opt into the Health Professionals Privilege Program or Educators Privilege Program by completing the online sign-up form available here (Health Professionals) or here (Educators). To participate, individuals must provide personal data including their name, email address, profession or educator status, and verification details confirming eligibility (such as professional credentials or employer information). This information is used to verify eligibility, administer the Program, and provide applicable Rewards and Offers. Participation is voluntary, and individuals may withdraw at any time in accordance with the applicable program terms. The full terms and conditions for these Programs are available here.

Other Programs. We may provide other Programs that may be considered financial incentives programs, including sweepstakes, contests and other promotional offerings or incentives. For example, we may make available Rewards and Offers to customers that participate in one of our customer satisfaction or market research surveys or requests for feedback (“Surveys”). To participate in a Program, you must register and provide us with certain personal data, which typically includes your name, email address and contact information, as well as your Survey responses (if applicable). Some of these Programs may be administered by third party partners who may collect or receive your personal data in order to administer the Program and provide related services to us.

4 EU and EEA Citizens

If you reside in the United Kingdom, EU, EEA, or Switzerland, you may request that we take the following actions in relation to your personal data according to the GDPR: 

  • Access. Provide you with information about our processing of your personal data and give you access to your personal data 
  • Correct. Update or correct inaccuracies in your personal data 
  • Delete. Delete your personal data 
  • Transfer. Transfer a machine-readable copy of your personal data to you or a third party of your choice 
  • Restrict. Restrict the processing of your personal data 
  • Data portability. You have the right to request for the receipt or the transfer to another organization, in a machine-readable form, of your personal data 
  • Object. Object to our legitimate interests as the basis of our processing of your personal data 
  • Right to withdraw consent. When you have given your explicit consent for the processing of your data, you can withdraw it at any time without justification 
  • You also have the right to lodge a complaint with your local Data Protection Authority or to the Data Protection Authority where the alleged infringement took place. 

You may submit a verifiable request via this link. You may update your preferences at any time via this link.

If you reside in the United Kingdom, EEA, or Switzerland and would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact our data protection privacy team (info@frankie4.com).

5 Changes to our privacy notice

From time to time, it may be necessary for Company to change its privacy notice, so we suggest that you check here periodically. Changes to the privacy notice will be notated by updates to the “Last Revised” date. Your continued use of the Website or Services constitutes your expressed agreement to any updates to this privacy notice. Please note that we will use commercially reasonable efforts to notify you of any material changes to this notice, but we always recommend routinely reviewing this notice.

6 Links to other sites

We may offer links to sites that are not operated by Company including our social media sites. If you visit one of these linked sites, you should review their privacy and other policies. We are not responsible for the policies and practices of other companies.

7 How to contact us

If you wish to contact us to update your information or complaints, please feel free to contact us: by telephone at (844) 364-4544 by email at info@frankie4.com

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