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CLO-SET & CLO-SET CONNECT

Privacy Policy

Last updated: Jul 20, 2021


CLO Virtual Fashion, LLC and its affiliates (“CLO”) respects the privacy rights of its users and protects the personally identifiable information collected, stored and used in connection with our websites and services—including CLO (also known as “CLO3D,” accessible at https://www.clo3d.com/), Marvelous Designer (accessible at https://www.marvelousdesigner.com/), CLO-SET (https://style.clo-set.com/aboutus), online stores (including the CLO-SET CONNECT Store and the MD Store), CLO’s parent website (https://www.clovirtualfashion.com/), the CLO Enterprise user training website, and other services that may be developed, modified, combined, and/or newly offered through our websites from time to time (our "Services").

To further this commitment, we have adopted this Privacy Policy ("Privacy Policy") to guide how we collect, store, and use the information you provide us. In this policy, any data processed by us or through the Services and qualifies as personally identifiable information under applicable law is referred to interchangeably as “Personal Information” or “Personal Data”.

By setting up a CLO account, by using our Services, by using or downloading software made available by CLO, or by clicking the “I accept” button (or its equivalent), you are accepting the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not register for an account with CLO, download software made available by CLO, or otherwise access our Services.

We may modify this Privacy Policy from time to time. We will notify you of any revisions to this Privacy Policy by posting the latest version here and by indicating the Last Modified date at the top. You will be deemed to have agreed to any such modifications by your continued use of our Services after any such modification is posted. It is important that you review this Privacy Policy regularly to ensure you are updated as to any changes. If you do not agree with the modifications, please discontinue use of our Services immediately.

We do not knowingly collect Personal Information from children under the age of 13. If you are a parent or guardian and believe your minor child has provided us with Personal Information without your consent, please contact us as at privacy@clo-set.com. and we will take steps to delete such Personal Information from our systems.

Personal Information will be processed in accordance with such applicable law, our Privacy Policy, and our various Terms of Service accessible at the above-listed websites for the applicable part of our Services that you use ) (“Terms”), on the lawful bases of Consent (e.g. your acceptance of our Privacy Policy), Legitimate Interest (e.g.. to ensure security and to ensure your compliance with this Agreement), and/or Performance of Contract (e.g. to deliver our Services as set forth in the Terms).

You should be aware that if we anonymize your Personal Information, it no longer qualifies as Personal Information and is not subject to this policy or the protections of applicable law. For the avoidance of doubt, you agree that we acquire ownership rights over such anonymized data. You also agree that if we aggregate your Personal Information, you give us a worldwide, royalty-free license to make commercial use of such aggregated, derived data. If you do not agree to this paragraph, please let us know at privacy@clo-set.com.

1. Scope of Privacy Policy

This Privacy Policy describes CLO’s collection and use of Personal Information submitted and collected through our Services. Personal Information includes any individually identifiable information about you, such as your name, address, telephone number, or e-mail address, and information concerning you collected and/or maintained in personally identifiable form.

Please be aware that websites with links to and from our Services may collect Personal Information about you. This Privacy Policy does not apply to, and cannot control the activities of, those other websites.

2. Information We Collect

We may collect and process the following data about you:

  1. • Personal Information such as your name, address, telephone number, e-mail address, and credit card number when you register for an account with CLO, make sales inquiries, request support, or make a purchase or payment.
  2. • We collect certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, operating system, browser type, date/time stamp, and/or program or system error messages and other system information. We may combine this automatically collected log information with other information we collect about you to improve our Services, to improve marketing, analytics, or website functionality.
  3. • If you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence.
  4. • We collect details of your use of our Services and the resources that you access. Such usage information includes information about how and when you access or use our Services.
  5. • User feedback, community discussions, chats and other interactions on our Services.
  6. • If you access our Services on your mobile telephone or other mobile device, including tablets, we collect mobile device identifiers, including MAC Address, and IP Address. Certain aspects of our Services will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, geo-location and any other information you choose to provide or allow us to access.
  7. • Contact information, Profile information (such as profile photo), other data you choose to give us.

Please see our CCPA Notice at the bottom of this page to see more details on the type of Personal Information we may have collected from you, as the data indicated in that section is not just limited to data we collect from California residents (the purposes, categories, sources, and uses of our data collection indicated in our CCPA Notice applies for all data subjects from whom we collect Personal Data or Personal Information).

Please keep in mind that when you voluntarily disclose Personal Information which is publicly viewable, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who views information (and what they do with information) you voluntarily post publicly.

3. How We Collect

CLO collects data from you when you choose to provide it to us directly, such as via an online form; when you provide it to us automatically (such as when you log in to access the online authentication version of our Software); or when you communicate with our customer support team. CLO and third parties also use certain technologies described below to collect data to deliver excellent experiences.

Cookies. Cookies are small text files placed on your device that can be recalled by a web server in the domain that placed the cookie. We use cookies for various purposes including to help recognize and remember you when you are logged into our Services so we can maintain your settings and preferences, analyzing the performance of our Services, maintain the integrity of our Services, and for other lawful bases. These cookies do not track your browsing activity on non-CLO related websites. For more information, please review our Cookie Policy. To manage your cookie preferences, please visit Cookie Settings.

Web Beacons. We also use “web beacons” to help deliver cookies and gather usage and performance data. Our website may include web beacons, cookies, or similar technologies from third-party service providers. By providing us with information about how you interact with our Services, these tools help us analyze and learn how to make our Services better and customize our communications with you. The following analytics technologies are in use: Google Analytics

Clear Gifs. We may also use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. For this reason, these types of clear gifs are tied to personally identifiable information.

You have access to tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your Internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies. However, if you disable cookies, your ability to use some features or areas of our Services may be affected.

CLO and our partners, such as marketing partners and analytics providers, may use tracking technologies such as cookies, beacons, tags and scripts. These technologies are used in analyzing trends, administering our websites, tracking users’ movements around the websites, and to gather demographic information about our user base as a whole. We use cookies for various purposes including our shopping cart, to remember users’ settings, and for authentication. Users can control the use of cookies by adjusting individual browser settings. However, if you reject cookies, you may still use our websites, but your ability to use some features or areas of our websites may be limited.

We may also use tools or third party analytical software to automatically collect and use certain non-Personal Information that does not directly enable CLO to identify you.

4. Use & Sharing of Information Collected

We use your Personal Information and non-Personal Information, both individually or combined together:

  1. • To help us manage, operate and deliver our Services to you
  2. • To improve your experience with our Services
  3. • To develop new products or services for you
  4. • To provide you with customer support
  5. • To communicate with you about our Services (unless you have not consented to allow us to use your information for these purposes)
  6. • For marketing and promotional purposes
  7. • For internal training purposes and statistical analysis
  8. • To keep our Services safe.

Except to the extent that third party targeted advertising cookies constitute a “sale” of Personal Information under applicable law, CLO does not sell Personal Information, including Personal Information of anyone under 16 years old. To the extent that third party advertising cookies constitute a “sale” of Personal Information under applicable law, you may opt-out of these third party targeted advertising cookies in Cookie Settings. You may also email privacy@clo-set.com with any questions or requests.

However, you hereby agree that CLO may, without seeking further your consent, share your Personal Information as follows:

  1. • With our affiliates to provide you our Services or information about other services and promotional materials.
  2. • With partners, vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Services are used, providing customer service, facilitating payments or conducting surveys. A list of subprocessors we use to support delivery of our Services is available at www.clo3d.com/subprocessors.
  3. • With other users of our Services in a way that is consistent with the functionality of our Services (e.g. your profile photo that you post on CONNECT).
  4. • if the ownership or control of all or part of our Services or their assets changes, with the new owner;
  5. • For other legitimate purposes, such as the purposes indicated at the bottom of this page in the CCPA Notice (the purposes, categories, sources, and uses of our data collection indicated in our CCPA Notice applies for all data subjects from whom we collect Personal Data or Personal Information).

We will encourage our service partners to adopt and post privacy policies. However, the use of your Personal Information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.

In a business transaction, such as a merger, acquisition, dissolution (including bankruptcy), change of control, or a sale of all or a portion of our assets, customer information, including Personal Information, generally is one of the transferred business assets. In the event that CLO undergoes such transactions, including preparation of any of such transactions, we may share, disclose or transfer all of your information, including Personal Information, to the successor. Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

Occasionally we may be required by law enforcement or judicial authorities to provide Personal Information to the appropriate governmental authorities. We will disclose Personal Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation.

5. Safeguards

CLO maintains appropriate safeguards that ensure the security, integrity, and privacy of the Personal Information we collect and store about our account holders. Personal Information collected by CLO is stored in secure operating environments that are not available to the public and that are only accessible by authorized employees. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control (i.e., maintain data quality). Before we allow web users to access their Personal Information, for example, we verify their identity by requesting that they submit information such as their username and password. We also take reasonable steps to ensure that third parties to whom we transfer Personal Information provide sufficient protection of such data.

Your Personal Information may be transferred to, and stored at, a destination outside the country of your residence. It may also be processed by personnel of our affiliates and third party service providers who may operate outside the country of your residence. In such a case, we will take reasonable steps to require such third party in possession of your Personal Information to take commercially reasonable security measures to protect the information.

However, unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be secure. As a result, while we strive to protect your Personal Information, you acknowledge that: (a) the security, integrity and privacy of any and all information and data exchanged between you and us through our Services cannot be guaranteed; and (b) any such information and data may be viewed or tampered with in transit by a third party.

6. Links to Third Party Sites or Services

You should be aware that our Services may from time to time contain links to third-party sites, products or services. CLO is not responsible for the privacy practices or the content of such sites or services. If you are concerned about the privacy policy of a certain third party, we recommend that you read the privacy policy of the site or service to which you link before you submit any Personal Information.

7. Your Rights Related to Personal Information and Access to Personal Information

You have certain rights regarding your Personal Information, subject to local data protection laws. These may include the following rights:

  1. • to access your Personal Information held by us (right to access);
  2. • to rectify inaccurate Personal Information and ensure it is complete (right to rectification);
  3. • to erase/delete your Personal Information to the extent permitted by other legal obligations (right to erasure; right to be forgotten);
  4. • to restrict our processing of your Personal Information (right to restriction of processing);
  5. • to transfer your Personal Information to another controller to the extent possible (right to data portability);
  6. • to object to any processing of your Personal Information carried out on the basis of our legitimate interests (right to object). Where we process your Personal Information for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
  7. • not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our websites; and
  8. • to the extent we base the collection, processing and sharing of your Personal Information on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

To exercise your rights, please contact us at privacy@clo-set.com. We try to respond to all legitimate requests within thirty (30) days and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than thirty (30) days, taking into account the complexity and number of requests we receive.

CLO makes good faith efforts to enable you to review, update or correct your Personal Information in our possession. In order to do so, please log into your account or contact privacy@clo-set.com. If you contact us, we will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request. Please note that even if Personal Information is changed or deleted according to your request, CLO may still retain some of your Personal Information to resolve disputes, enforce CLO user agreement(s), and comply with technical and legal requirements and constraints related to the security, integrity and operation of our Services.

8. Retention; Deactivated or Terminated Accounts

Please be aware that even after your account is terminated or deleted, some or all of your information may still remain visible to others. A request to delete and/or terminate your account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to us. We are not able nor are we obligated to remove any of your information from a third party provider or platform. Moreover, please be aware that even after you delete your account or your account is terminated, your information may not be deleted in its entirety from our servers and servers of the third party with whom such information have been shared

When you sign up for an account with CLO, CLO retains Personal Information you store on our Services for as long as your account is in existence or as long as we need it to provide you our Services. If you delete your account, we will initiate deletion of this information after 30 days, but please note: (1) there might be some latency in deleting this information from our servers and back-up storage; (2) a request to delete and/or terminate your account will not result in the removal of information collected and already put in aggregate form; (3) we are not able nor are we obligated to remove any of your information from a third party provider or platform; and (4) we may retain your information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

9. Opting Out

If at any time you wish to opt out of having your Personal Information shared with third parties and/or receiving information from CLO (via e-mail or postal mail) about new products, services, or promotions, you can do so by adjusting your account settings, by clicking “unsubscribe here”, “manage your preferences”, or their functional equivalent, or by emailing us at privacy@clo-set.com.

10. International Privacy Practices

The CLO-SET Service is provided through and managed on servers located and operated within the United States. By using and accessing our Services, residents and citizens of countries and jurisdictions outside of the United States agree and consent to the transfer, storage and processing of your information on servers located in the United States.

Specifically, CLO-SET leverages a data center in the United States hosted by Amazon Web Services, Inc. (AWS).. On May 22, 2018, AWS incorporated the AWS GDPR Data Processing Addendum (DPA) into its online Service Terms.

This means that you can rely on the terms of the AWS GDPR DPA which will apply automatically from May 25, 2018 whenever we use the AWS services to process Personal Data under the GDPR, including the transfer of Personal Data outside of the European Economic Area (“EEA”).

The AWS GDPR DPA includes the EU Model Clauses and the Standard Contractual Clauses to enable the transfer of data outside of Europe. The AWS GDPR DPA applies automatically whenever we require it to comply with the GDPR. More details can be found at https://aws.amazon.com/blogs/security/aws-gdpr-data-processing-addendum/.

11. Inquiries

If you have any questions or wish to file a complaint, please feel free to email us at privacy@clo-set.com.

CLO’s Notice to California Residents

Last updated: July 20, 2021



The California Consumer Privacy Act of 2018 (“CCPA”) gives California residents (“you”) rights and control over their Personal Information. CLO Virtual Fashion, LLC and its affiliates (“CLO,” “we,” “our”) provides this statement to those residents (“you”) in accordance with requirements under the CCPA to make certain disclosures about the collection and processing of their Personal Information.

This is CLO’s California-specific description of consumers’ privacy rights under the CCPA (the “CCPA Notice”).

What is Personal Information?

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

Cookies and Selling

Under the CCPA, a business that sells California resident’s Personal Information to others: (1) must give notice to California residents before selling their Personal Information to others; and (2) must provide the right to opt out of the sale of their Personal Information. This site uses cookies, such as Google Analytics, and similar technologies. Cookies can store preferences, make a site more user-friendly, and collect information about site usage and performance. Targeted third party advertising cookies are a particular type of cookies that support internet-based advertising.

This site uses third party advertising cookies (which are optional), as we seek to provide relevant marketing messages related to our products and services. Please see our Cookie Policy for more details and please visit Cookie Settings to disable optional cookies and otherwise manage your cookie preferences.

Except to the extent that third party targeted advertising cookies constitute a “sale” of Personal Information under applicable law, CLO does not sell Personal Information, including Personal Information of anyone under 16 years old. To the extent that third party advertising cookies constitute a “sale” of Personal Information under applicable law, you may opt-out of these third party targeted advertising cookies in Cookie Settings. You may also email privacy@clo-set.com with any questions or requests.

Your rights under the CCPA

The CCPA provides California residents with certain rights related to their Personal Information. To submit a request based on these rights, please contact us at privacy@clo-set.com.

When receiving a request, we will verify that the individual making the request is the resident to whom the Personal Information subject to the request pertains. California residents may exercise their rights themselves or may use an authorized agent to make requests to disclose certain information about the processing of their Personal Information or to delete Personal Information on their behalf. If you use an authorized agent to submit a request, we may require that you provide us additional information demonstrating that the agent is acting on your behalf.

In some instances, we may decline to honor your request where a CCPA exception applies. For example, we do not have an obligation under the CCPA to disclose or delete information as described above with respect to information that we collected about a job applicant or employee that we use solely within the context of the individuals’ role or former role as a job applicant or employee. In addition, we may decline to delete Personal Information that we collected from you if retaining the information is necessary for us to, for example, (1) provide a good or service you requested; (2) detect, or investigate security incidents; or (3) protect against fraud or license abuse.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

With respect to your Personal Information, you may exercise the rights described below.

1. Right to know what Personal Information is being collected, for what purposes, and with whom it is shared

California residents have the right to request from a business disclosure of:

  1. • the categories and specific pieces of information it has collected from them in the preceding 12 months,
  2. • the categories of sources from which such Personal Information is collected,
  3. • the business or commercial purpose for collecting or selling such Personal Information, and
  4. • the categories of third parties with whom the business shares Personal Information.

If you request that a business disclose categories and specific pieces of Personal Information collected about you, you have the right to receive that information, free of charge, twice a year. The information may be delivered by mail or electronically—and, if provided electronically, shall be in a portable and, to the extent technically feasible, readily usable format that allows the California resident to relatively easily transmit this information to another entity.

2. Right to know whether your Personal Information is sold or disclosed for a business purpose and to whom

California residents have the right to request from a business that sells or discloses Personal Information for a business purpose separate lists of the categories of Personal Information collected, sold, or disclosed for a business purpose in the preceding 12 months, including the categories of third parties to whom Personal Information was sold or disclosed for a business purpose.

3. Right to say no to the sale of your Personal Information

As explained above, the CCPA requires businesses that sell Personal Information to allow residents the ability to opt out of the selling of their information.

Except to the extent that third party targeted advertising cookies constitute a “sale” of Personal Information under applicable law, CLO does not sell Personal Information, including Personal Information of anyone under 16 years old. To the extent that third party advertising cookies constitute a “sale” of Personal Information under applicable law, you may opt-out of these third party targeted advertising cookies in Cookie Settings. You may also email privacy@clo-set.com with any questions or requests.

4. Right to non-discrimination of service or price if you exercise your privacy rights

CThe CCPA prohibits businesses from discriminating against a California resident for exercising any of their rights under the CCPA, including by:

  1. • Denying goods or services
  2. • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or by imposing penalties
  3. • Providing a different level or quality of goods or services
  4. • Suggesting that the person exercising their rights will receive a different price or rate for goods or services or a different level or quality of goods or services

5. Right to deletion

California residents have the right to request that a business delete any of their Personal Information that the business collected from them, subject to the exceptions in CCPA Section 1798.105.

Our Collection, Use, and Disclosure of Personal Information

We collect Personal Information relating to California residents in a variety of contexts, including, for example, collecting Personal Information relating to individuals who may be eligible for CLO products or services but who do not have an existing customer or customer relationship with us, apply for employment with us or who are our employees, vendors, contractors, or similar personnel, who are beneficiaries or dependents of our employees, or enter into our contests and promotions. The specific Personal Information that we collect, use, and disclose relating to a California resident will depend on our specific relationship or interaction with that individual.

Category of Personal Information Collected in the Last 12 Months

In the past 12 months, we have collected the following categories of Personal Information relating to California residents:

  1. Identifiers, such as real name, alias, mailing address, unique personal identifier, online identifier, IP address, email address, account name, Social Security Number, or other similar identifiers.
  2. • Personal Information as defined in the California customer records law, such as name and social security number, and username or email address in combination with a password.
  3. Characteristics of protected classifications under California or federal law, such as gender and date of birth.
  4. Commercial information, such as products or services purchased or obtained, and similar transaction and account information.
  5. Internet or network activity information,such as interactions with our Services or websites.
  6. Geolocation data, such as IP addresses
  7. Audio, electronic, visual, or similar information, such as call and video recordings of Training Workshops or user profiles.
  8. Professional or employment-related information, such as job title and work history.
  9. Education information, subject to the federal Family Educational Rights and Privacy Act, such as student enrollment in certain courses.
  10. Inferences drawn from any of the information identified above to give you a more personalized web experience (i.e. through the use of cookies pursuant to our Cookie Policy).

Category of Sources from which the Personal Information has been Collected in the Past 12 Months

  1. • Information that you and/or other consumers choose to provide directly to us
  2. • Information that you and/or other consumers choose to provide us through interaction with our services and/or websites

Business or Commercial Purpose(s) for Collecting the Personal Information in the Past 12 Months

The purposes for which we use Personal Information that we collect depends on our relationship or interaction with a specific California resident. We may use Personal Information:

  1. • to operate, manage, and maintain our business;
  2. • to provide our products and services; and
  3. • for our employment and vendor management purposes.

In addition, we may use Personal Information to accomplish our business or commercial purposes and objectives, including, for example, using Personal Information to:

  1. • detecting security incidents;
  2. • detect and prevent fraud and/or license abuse;
  3. • protecting against malicious, deceptive, fraudulent, or illegal activity (and prosecuting those responsible for that activity);
  4. • debugging to identify and repair errors that impair existing intended functionality of our services and/or products;
  5. • develop and market our products and services;
  6. •undertaking research and data analysis for technological development and demonstration
  7. • undertaking activities to verify or maintain the quality or safety of a service or product, and to improve, upgrade, or enhance our services and/or products
  8. • maintain our facilities, systems, and infrastructure;
  9. • perform accounting, audit, and other internal functions (such as internal investigations);
  10. • comply with law, legal process, and internal policies;
  11. • maintain business records; and
  12. • exercise and defend legal claims.

Categories of Third Parties with Whom the Personal Information Was Shared In the Past 12 Months

  1. • Our affiliates
  2. • Service providers and contractors
  3. • Law enforcement
  4. • Applicable customers and/or users
  5. • Others to whom you have chosen to disclose through our services and/or websites

Categories of Personal Information that have been Disclosed for a Business or Commercial Purpose in the Past 12 Months

In the past 12 months, we have disclosed the following categories of Personal Information relating to California residents to third parties for our business or commercial purposes:

  1. Identifiers, such as real name, alias, mailing address, unique personal identifier, online identifier, IP address, email address, account name, Social Security Number, or other similar identifiers.
  2. • Personal Information as defined in the California customer records law, such as name and social security number, and username or email address in combination with a password.
  3. Characteristics of protected classifications under California or federal law, such as gender and date of birth.
  4. Commercial information, such as products or services purchased or obtained, and similar transaction and account information.
  5. Internet or network activity information, such as interactions with our Services or websites.
  6. Geolocation data, such as IP addresses
  7. Audio, electronic, visual, or similar information, such as call and video recordings of Training Workshops or user profiles.
  8. Professional or employment-related information, such as job title and work history.
  9. Education information, subject to the federal Family Educational Rights and Privacy Act, such as student enrollment in certain courses.
  10. Inferences drawn from any of the information identified above to give you a more personalized web experience (i.e. through the use of cookies pursuant to our Cookie Policy).

Exemptions under the CCPA

The CCPA provides exemptions, until and including December 31, 2020, from certain of the above described disclosures pertaining to the last 12 months including a business-to business exemption: Personal Information reflecting a written or verbal communication or transaction between CLO and a natural person, where the natural person is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or a governmental agency and whose communications or transaction with CLO occur solely within the context of CLO conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, nonprofit, or government agency.

If you have any questions, please contact us at privacy@clo-set.com.

Changes to this California Consumer Privacy Act Notice

We may change or update this Notice from time to time. When we do, we will post the revised Notice on this page with a new “Last revised” date.