Privacy Policy

We at Magic Retail Labs Inc. (collectively, “Dillo,” “we,” “us,” or “our”) with our main place of business at 3243 Spider Lily, San Antonio TX 78258, respect your privacy and are committed to protecting your personal information.

This Privacy Policy (“Policy”) describes our policy and code of conduct for the information we collect, use, process, maintain, and disclose from your use of our websites, mobile apps, products, and services (collectively, “Services”). This information includes information that can be associated with a person/or could be used to identify a person (“Personal Data”), as well as information that does not relate to a person or cannot be used to identify a person (“Non-Personal Data”). The limitations and requirements in this policy on our collection, use, processing, disclosure, transfer, and storage/retention of Personal Data do not apply to Non-Personal Data.

By visiting our physical stores, websites, mobile apps, or using any of our products or services, you agree that your personal information will be handled as described in this policy.

Table of Contents

1. 1. Personal Data We Collect

2. 2. How We Use the Personal Data We Collect

3. 3. How We Disclose and Transfer Your Personal Data

4. 4. How We Secure Your Personal Data

5. 5. Choices You Have Regarding Your Personal Data

6. 6. Retention of Your Personal Data

7. 7. Cookies, Web Beacons, and Other Technologies

8. 8. Children

9. 9. International Privacy Laws

10. 10. Privacy Shield

11. 11. Terms of Service

12. 12. Exclusions

13. 13. Changes to This Privacy Policy

14. 14. Contacting Us

15. 15. Your Local Privacy Rights

Personal information may be requested any time you contact Dillo or a Dillo affiliated company. It may also be requested by the Dillo Mobile App, the Dillo Web Portal, a Dillo Store Kiosk, or a Dillo Customer Service Representative. In any and all cases, your disclosure of such information is purely voluntary. Dillo and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising.

We reserve the right to change any provision of the Privacy Policy at any time. We will either post on the website or send out a notice or both when changes have been made to the Privacy Policy that materially affect you, and indicate by what time those changes will be implemented, unless otherwise dictated by law. You are encouraged to review the Privacy Policy from time to time.

1. Personal Data We Collect

1.1 Personal Data You Provide Us

Personal Data is information that can be used to specifically or explicitly identify or contact a single person. When providing you Services, there is some Personal Data that You voluntarily provide to Us. This may include your name, telephone number, address, email address and contact preferences when you create an account, register for special services, download updated software or participate in a survey, or contact customer support. When using the Dillo web portal, Dillo mobile app, a Dillo Store Kiosk, or the Dillo Stores, you may also choose to voluntarily disclose Personal Data such as a month and year of birth, preferred gender, and provide a picture or avatar for your account profile.

1.2 Personal Data We Collect Automatically

When you visit our website or use our services, we collect information sent to us by the means with which you contacted us, such as your computer, mobile phone or other device used to access us or the services. The information sent to us includes data on the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information. Web log data includes the browser type you are using and traffic to and from our site. When you visit the Dillo website or use the Dillo Services, we may also collect information about your transactions and your activities.

In the case you take advantage of our gifting services, sending information, gift certificates or products, or invite others to join the services, Dillo may collect the information you provide about those people such as name, address, email address, and telephone number.

In certain cases, we may work with social media sites. Information received from social media sites is controlled by them, and if information from a social media site is sent to us, you agree that we may collect store and use this information in accordance with our own Privacy Policy.

We use cameras as part of our machine vision platform, which means we receive video footage of you at all times when you are using a Dillow Store in order to make the unattended retail solution work, as well as for security and quality assurance purposes, and for our use as described in this Privacy Statement. While we are capturing and may store such video footage, we are not capturing or using your biometric information.

2. How We Use The Personal Data We Collect

We use your personal information to provide you services, and to complete transactions by using the services. We may also use your personal information for communications; from time to time, we may use your personal information to send updates and important notifications, such as changes to our documentation (terms conditions policies and procedures) and because this communication pertains to the provision of your services, you may not opt out of receiving these updates. We may also use your personal information to improve our products, content and services. In the case of promotions of any kind, Dillo may use your given personal information to administer such promotions and to send you targeted marketing and promotional offers based on your preferences. Images captured by the Dillo Store are used only for running our unattended retail solution, as well as for security, quality assurance, and auditing purposes.

3. How We Disclose and Transfer Your Personal Data

3.1 Not Selling Your Personal Data

We consider your trust in us regarding your Personal Data to be an important part of our relationship with you. Therefore, we will not sell your Personal Data to third parties, including third party advertisers. There are some circumstances, however, where we may disclose, transfer, or share your Personal Data with a third party without notice to you, as described below.

3.2 Business Transfers

There may come a time where we sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Personal Data may be considered part of the transferred assets. By using our Services, you acknowledge and agree that any successor to Dillo (or its assets) will continue to have the right to use your Personal Data in accordance with this Privacy Policy.

3.3 Parent Companies, Subsidiaries, and Affiliates

We may share your Personal Data with our parent companies, subsidiaries, and/or affiliates for purposes according to this Privacy Policy. Any Personal Data shared with our parent companies, subsidiaries, and/or affiliates will be done so in a manner consistent with the Privacy Policy.

3.4 Contractors, Consultants, and Service Providers

We may share your Personal Data with our contractors, consultants, and service providers who process Personal Data on behalf of Dillo to perform certain business-related functions and may be located wherever Dillo operates. These companies may include, but are not limited to, marketing agencies, database service providers, backup and disaster recovery service providers, email service providers, and others. When we engage another company to perform such business-related functions that may require access to Personal Data, these companies will agree to maintain the confidentiality, security, and integrity of such Personal Data in accordance with this Privacy Policy. Access to Personal Data that these companies receive will be limited to only Personal Data needed to successfully complete the business-related function they have been engaged by us for unless you expressly permit them to use your information for other purposes. Dillo will not sell, lease, trade, or otherwise profit from your Personal Data.

3.5 Dillo Customers and Partners

In the case that a Dillo Store is ran by a company other than Dillo itself, Dillo may share this information with such party from whom You are buying goods or services from. Any Personal Data shared with our customers will be done so in a manner consistent with the Privacy Policy.

3.6 Legal Requirements

We may disclose your Personal Data if required to do so by law in order to respond to a subpoena or request from law enforcement, a court, or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect or defend our rights, interests, or property, or that of third parties, (iii) prevent or investigate possible wrongdoing in connection with our Services, (iv) act in urgent circumstances to protect the personal safety of users of our Services or the public, or (v) protect against legal liability.

4. How We Secure Your Personal Data

We take your security seriously and strive to take reasonable steps to protect your information. No data transmission over the internet or information storage technology can be guaranteed to be 100% secure. The following is a summary of the measures we take to protect the Personal Data you provide us and an explanation of ways we implement these measures. We continue to evaluate and implement enhancements in security technology and practices, however we can only take steps to help reduce the risks of unauthorized access. You can also take steps to protect your information and further minimize the likelihood that a security incident may occur.

4.1 Secure Socket Layer

We use Secure Socket Layer (“SSL”) encryption when transmitting certain kinds of information, such as payment information or Personal Data. An icon resembling a padlock is displayed in most browsers’ window or address bar during SSL transactions. For example, any time we ask for a credit card number for payment or for verification purposes, it will be SSL encrypted in its transmission to our third party payment gateways, like Stripe or others. The information you provide will be stored securely on those gateways’ services. Once you choose to store or enter your credit card number in our Services, it will not be displayed back in entirety for any users. Instead of the entire number, you will only see asterisks and either the first four digits or the last four digits of your number.

4.2 Secure Storage

We maintain reasonable physical, electronic, and procedural safeguards that comply with federal regulations to protect personal information about you.

4.3 Vendors and Partners

We work with vendors and partners to protect the security and privacy of user information. We host our Services on Google Cloud, who maintains its own procedures and controls to ensure data security. Details can be found athttps://cloud.google.com/security/

4.4 Employee and Contractor Access to Personal Data

We limit access to personal information about you only to those trained employees who we reasonably believe need to come into contact with that information to provide products and services to you in order to do their jobs.

5. Choices You Have Regarding Your Personal Data

5.1 Accessing, Updating, Correcting, or Deleting Your Personal Data

Upon request, we will provide you with information about whether we maintain, or process on behalf of a third party, any of your Personal Data. If your personal information changes, the Personal Data we collected about you is inaccurate, or if you wish to no longer use our services, you may also request that your Personal Data be corrected, amended, or deleted. Requests for access to your Personal Data and to have it corrected, amended, or deleted should be sent to support@Dillostores.com or writing to us at Magic Retail Labs Inc., 3243 Spider Lily, San Antonio, TX 78258.

We will try to meet all requests regarding Personal Data, however, you may not be able to remove your personal information from archived web pages we no longer maintain. If we are unable to complete your access request, we will let you know we are unable to do so and why. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

If your information has been shared with a third party, as described above, then that third party has received their own copy of your data. If you have been contacted by one of these third parties and wish to correct or request they delete your information, please contact them directly.

5.2 Limiting the Personal Data You Provide

You can browse or use our Services without providing any Personal Data (other than data automatically collected to the extent it is considered Personal Data under applicable laws) or by limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services.

5.3 Opting Out of Electronic Communications

Dillo may send you electronic communications marketing or advertising through the Services themselves or events on the Services. When you use our Services, you have the option of signing up for Newsletters or to request further information. If at any time you would like to stop receiving the information that you have requested to receive from us, you may follow the opt-out instructions contained in any such electronic communication. In the case of the Dillo mobile app and Dillo web portal solutions you may also manage your email preferences at any time through your account.

If you opt-out of receiving emails or promotions from us, we may still send you emails about your account or any Services you have requested or received from us, or for other customer services purposes. In addition, you may still receive emails sent by third parties through means other than our Services.

Please be aware that you cannot unsubscribe from update communications about our Services unless you deactivate your account.

6. Retention of Your Personal Data

Should you wish to close your account and end your relationship with Dillo, we will “close” such account, but retain personal information to collect fees or redeem value, resolve disputes, or assist with any action required or permitted by law. To close your account please email support@Dillostores.com or write to us at Magic Retail Labs Inc., 3243 Spider Lily, San Antonio, TX 78258. Even after you opt-out of all communications, we will retain your Personal Data in accordance with this Privacy Policy, as provided under “6. Retention of Your Personal Data”, though we will no longer use it to contact you. However, third parties who have received your Personal Data in accordance with this Privacy Policy may still use that Personal Data to contact you in accordance with their own privacy policies. You will need to contact those third parties in order to have your information deleted from their records as well.

7. Cookies, Web Beacons, Etc.

7.1 What Cookies and Web Beacons Are

Cookies are small data files placed onto your computer or mobile device when you visit a website which allows our Services to distinguish you from other users, allow the Services to work properly, as well as to help monitor your usage of our websites, apps, and services. Web beacons work similar to cookies, however, instead of a file stored on your computer, web beacons are embedded invisibly on web pages. We use cookies, web beacons, tags, and other similar tracking technologies to track when you visit our websites and mobile applications (collectively, “Cookies”).

7.2 How We Use Cookies

There are several reasons we use Cookies on our Services. Some of these Cookies are necessary for technical reasons and help our Services to operate as intended for your benefit (“Essential Cookies”), such as access to secure areas of the Services. Other types of Cookies are used for analytical purposes such as how our Informational Websites and/or Services are being used, and to customize content and internal advertising to you (“Analytical Cookies”). While these types of Cookie help us to create new features, improve on our existing Services, and provide advertisements of interest to you, our Services can function without them.

7.3 Controlling Cookies

You have the right to decide whether to accept or reject Cookies. You can exercise your Cookie preferences by activating the setting on your web browser that allows you to refuse the setting of all or some Cookies. However, if you use your browser settings to block all cookies (including Essential Cookies), you may not be able to access or use all or parts of our Services. If you have not adjusted your browser setting so that it will refuse cookies, our system will issue Cookies as soon as you visit our Services. Blocking or deleting Cookies will not prevent device identification and related data collection from occurring when you access our Services. Turning off Analytical Cookies will prevent their ability to measure the relevance and effectiveness of our Services, emails, and advertising as well as to show you tailored advertising, however this does not mean you will no longer see any advertisements when you use our Services.

8. Children and Minors

The Children’s Online Privacy Protection Act of 1998 and its rules (“COPPA”) requires us to inform parents and legal guardians about our practices for collecting, using, and disclosing personal information from children under the age of thirteen (13). In some countries or jurisdictions, even higher age limits may apply. Dillo does not intend to collect Personal Data from children under the age of thirteen (13), or the otherwise applicable age limit if different in your country or jurisdiction of location, and expressly hereby prohibits Children under such age to create accounts. If you are aware of a user under the age of thirteen (13) who has provided Personal Data through our Services, please contact us at support@Dillostores.com

9. International Privacy Laws

This clause has been Intentionally Left Blank as Dillo is only present in the United States of America at the time of this Privacy Policy update.

10. Privacy Shield

This clause has been Intentionally Left Blank as Dillo is only present in the United States of America at the time of this Privacy Policy update.

11. Terms of Use

Your use of our Services, as well as any dispute over privacy, is subject to this Privacy Policy and our Terms of Service, available athttp://www.Dillostores.com/legal/

12. Exclusions

12.1 Third Party Sites And Services

Our website, mobile application links to third party websites and locations, and encourage use of their services. Our products and services may contain offers or offer products and services from third parties. Any information gathered by third parties is governed by those third parties’ privacy policies. You are encouraged to verify the privacy policy of every service you use.

12.2 Aggregated Personal Data

In an ongoing effort to better understand and serve the users of our Services, we often conduct research on our customer demographics, interests, and behavior based on Personal Data and other information that we have collected. This research may be compiled and analyzed on an aggregate basis and this aggregate information does not identify you personally and we therefore consider and treat this data as Non-Personal Data.

13. Changes to This Privacy Policy

Dillo reserves the right to update or modify this Privacy Policy at any time. If we make changes to this Privacy Policy, we will post the revised Privacy Policy to our website with a changed “Last Updated” date at the bottom of this Privacy Policy. All changes are effective 30 days after posting. Your continued use of Services following the effectiveness of any changes constitutes acceptance of those changes. If you do not agree with any of the changes to the Privacy Policy, you should cease accessing, browsing, and otherwise using of the Services we provide, and close your account.

14. Contacting Us

Who To Talk To About Your Privacy Questions

If you have any questions comments or concerns regarding this privacy policy, please contact us at support@Dillostores.com or writing to us at Magic Retail Labs Inc., 3243 Spider Lily, San Antonio, TX 78258

15. Your Local Privacy Rights

15.1 Do Not Track

Our Services are not currently configured to respond to browsers’ “Do Not Track” signals because at this time no formal “Do Not Track” standard has been adopted.

15.2 Other US State Regulations

15.2.1 California Residents

15.2.1.1 California Consumer Privacy Act

The California Consumer Privacy Act provides California residents with the right to know what categories of personal information Dillo has collected about them acting in its capacity as a “business”:

15.2.1.2 “Shine Your Light”

California residents may request a list of all third parties to which Dillo has disclosed certain personally identifiable information about you for marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information by contacting us at: support@Dillostores.com or writing to us at Magic Retail Labs Inc., 3243 Spider Lily, San Antonio, TX 78258

Magic Retail Labs Inc., Last Updated: December 21st, 2022