Privacy Policy

Information You Provide

We may collect information that you voluntarily provide when you:

1. submit a contact form;
2. email us;
3. join a mailing list;
4. subscribe to communications;
5. participate in a promotion, sweepstakes, contest, competition, giveaway, or other activity;
6. request information;
7. communicate with Bella Ora or a participating Bella Ora brand;
8. attend or register for an event;
9. respond to a survey;
10. provide feedback;
11. submit a review or testimonial;
12. participate in a community or other interactive feature;
13. pursue a business, partnership, sponsorship, vendor, employment, or other relationship with us; or
14. otherwise communicate or interact with Bella Ora.

Depending on the interaction, this information may include:

1. name;
2. email address;
3. telephone number;
4. mailing address;
5. company or organization;
6. job title;
7. business information;
8. interests;
9. brand interests;
10. communication preferences;
11. promotion or competition information;
12. eligibility information;
13. the subject and content of an inquiry;
14. social-media information you voluntarily provide;
15. relationship history;
16. transaction-related information where applicable;
17. information contained in correspondence with us; and
18. other information you choose to provide.

Sensitive Information

Bella Ora's general corporate website forms are not intended for the collection of unnecessary sensitive personal information.

Unless Bella Ora specifically requests information for a legitimate and disclosed purpose, please do not submit through a general contact form information such as:

1. passwords;
2. Social Security numbers;
3. government identification numbers;
4. complete payment-card information;
5. financial account credentials;
6. sensitive health information; or
7. other highly sensitive personal information.

Certain Bella Ora brands, transactions, competitions, regulated activities, or services may legitimately require additional or sensitive information. Where appropriate, those services may provide additional disclosures, consent mechanisms, terms, or safeguards.

Website, Device, and Usage Information

Depending on the technologies in use and your privacy choices, Bella Ora and its service providers may automatically collect information such as:

1. IP address;
2. browser type;
3. device type;
4. operating system;
5. referring website;
6. pages viewed;
7. landing pages;
8. exit pages;
9. links clicked;
10. date and time of visits;
11. approximate geographic location derived from technical information;
12. campaign attribution information;
13. referral information;
14. UTM or similar campaign parameters;
15. interactions with website features;
16. cookie or similar technology identifiers; and
17. other technical and usage information.

Information From Participating Bella Ora Brands

Bella Ora may receive information from participating Bella Ora brands and combine that information within the Bella Ora relationship ecosystem.

This allows Bella Ora to maintain a more complete and useful understanding of a person's relationship with Bella Ora and its participating brands, subject to applicable privacy laws and the preferences described in this Policy.

Information From Offline Interactions

Bella Ora may combine online information with information obtained through lawful offline interactions, including:

1. events;
2. trade shows;
3. conferences;
4. telephone conversations;
5. SMS or text communications;
6. WhatsApp or similar messaging services;
7. business correspondence;
8. referrals;
9. direct business relationships;
10. meetings; and
11. other lawful interactions.

Information From Public and Third-Party Sources

Where permitted by law, Bella Ora may collect or receive information from sources such as:

1. publicly available sources;
2. business directories;
3. professional or social profiles;
4. referral partners;
5. participating Bella Ora brands;
6. service providers;
7. event organizers;
8. marketing or technology providers;
9. lawful commercial data providers; and
10. other third-party sources.

We may use this information to update, verify, supplement, enrich, or better understand existing relationship information.

Bella Ora may use personal information to:

1. respond to inquiries and fulfill requests;
2. connect you with the appropriate Bella Ora brand or team;
3. evaluate partnership, sponsorship, vendor, investment, employment, or business opportunities;
4. provide requested information;
5. manage our relationship with you;
6. maintain business contacts;
7. administer promotions and competitions;
8. verify eligibility for promotions or services;
9. operate and improve our websites, platforms, products, and services;
10. provide customer, participant, or user support;
11. personalize content and communications;
12. understand interests and preferences;
13. perform analytics;
14. measure website and marketing performance;
15. perform campaign attribution;
16. segment audiences;
17. prioritize inquiries or leads;
18. enrich customer, prospect, or relationship records;
19. recommend relevant Bella Ora brands, content, products, services, events, or opportunities;
20. coordinate relationships across participating Bella Ora brands;
21. send marketing communications where permitted;
22. manage privacy and communication preferences;
23. conduct research and business planning;
24. prevent fraud, spam, manipulation, misuse, and unauthorized access;
25. protect promotions and competitions from abuse;
26. secure our systems;
27. maintain records;
28. comply with contractual obligations;
29. comply with legal, regulatory, accounting, and tax obligations;
30. resolve disputes;
31. establish, exercise, or defend legal claims; and
32. protect the rights, property, safety, security, and integrity of Bella Ora, participating brands, users, business partners, and others.

Where applicable law requires consent for a particular activity, Bella Ora will obtain that consent.

Bella Ora is designed to operate as a connected house of brands rather than as a collection of completely isolated businesses.

Information collected through one participating Bella Ora brand may therefore be used within Bella Ora, where permitted by law, to:

1. maintain a unified relationship record;
2. understand engagement across participating brands;
3. identify relevant interests;
4. route inquiries;
5. avoid unnecessary duplication;
6. improve customer and user experiences;
7. personalize communications;
8. perform segmentation;
9. recommend relevant brands, products, content, services, or opportunities;
10. measure cross-brand activity;
11. maintain privacy and communication preferences; and
12. improve Bella Ora's businesses.

This does not mean that every Bella Ora brand may disregard a person's privacy or communication preferences.

Bella Ora may maintain preferences at:

1. the Bella Ora level;
2. the individual brand level;
3. the communication-channel level; and
4. where appropriate, the specific service or activity level.

Where permitted by applicable law, Bella Ora may communicate with you based on:

1. your relationship with Bella Ora or a participating Bella Ora brand;
2. a request or inquiry you initiated;
3. your participation in a promotion, event, competition, service, or transaction;
4. your communication preferences;
5. consent you provided; or
6. another lawful basis recognized by applicable law.

Bella Ora may communicate through channels including:

1. email;
2. SMS or text messaging;
3. telephone;
4. WhatsApp or similar messaging platforms;
5. account or service notifications;
6. social or digital messaging services; and
7. other communication channels.

Where affirmative consent is legally required for a particular communication channel or type of marketing, Bella Ora will obtain that consent.

Cross-Brand Marketing

Where permitted by law and consistent with your preferences, Bella Ora may send marketing communications concerning participating Bella Ora brands, including a Bella Ora brand other than the brand with which you originally interacted.

Communication preferences may be maintained separately for individual brands and communication channels.

Global Marketing Opt-Out

You may choose to stop all Bella Ora marketing communications.

A global marketing opt-out will suppress marketing communications from Bella Ora and participating brands covered by the centralized preference system unless you later affirmatively re-subscribe.

If you later affirmatively opt into marketing from a particular Bella Ora brand, that action may reactivate marketing for that particular brand without automatically reactivating marketing from every Bella Ora brand.

Marketing Preference Methods

You may manage applicable preferences at:

www.bella-ora.com/privacy-preferences

You may also email:

hello@bella-ora.com

You may additionally use an unsubscribe mechanism included in applicable marketing communications.

Bella Ora may retain limited suppression information after an opt-out in order to continue honoring your preference.

Transactional and Nonmarketing Communications

Marketing opt-outs do not prevent Bella Ora from sending communications reasonably necessary for:

1. responding to an inquiry;
2. fulfilling a request;
3. administering a transaction;
4. operating an account;
5. administering a promotion or competition;
6. delivering a prize;
7. providing customer support;
8. security;
9. fraud prevention;
10. legal notices;
11. service notices; or
12. other nonmarketing purposes.

Bella Ora or a participating Bella Ora brand may operate or sponsor:

1. sweepstakes;
2. giveaways;
3. skill-based contests;
4. challenges;
5. competitions;
6. promotional campaigns; and
7. similar activities,

collectively referred to in this Privacy Policy as "Promotions."

Participation may require us to collect information necessary to:

1. administer entries;
2. identify participants;
3. determine eligibility;
4. verify age or geographic eligibility;
5. prevent fraud or duplicate entries;
6. detect manipulation or abuse;
7. select, judge, or verify winners;
8. communicate with participants;
9. announce winners where permitted;
10. deliver prizes;
11. obtain required releases;
12. satisfy tax or reporting obligations; and
13. comply with applicable law and Official Rules.

A Promotion may establish a marketing relationship with Bella Ora or a participating brand where legally permitted and clearly disclosed.

Where separate affirmative consent is required for marketing, Bella Ora will obtain that consent.

Each Promotion may be governed by separate Official Rules, entry terms, platform disclosures, consent language, and supplemental privacy disclosures.

Those more specific terms control with respect to the Promotion to the extent they address a specific practice differently.

Bella Ora may use automated technologies, analytics systems, artificial intelligence, or other software-assisted tools to support legitimate business functions such as:

1. website analytics;
2. audience segmentation;
3. personalization;
4. recommendations;
5. search and discovery;
6. campaign measurement;
7. marketing attribution;
8. lead scoring;
9. lead prioritization;
10. CRM enrichment;
11. relationship intelligence;
12. customer support;
13. fraud detection;
14. abuse prevention;
15. security; and
16. product and service improvement.

These tools may process information provided by you, information generated through your interaction with Bella Ora, or information lawfully obtained from other sources.

Bella Ora does not currently use automated decision-making through the general Bella Ora corporate website to make decisions that produce legal or similarly significant effects concerning matters such as credit, employment, housing, insurance, or other comparable high-impact decisions, unless separately disclosed.

Where applicable privacy laws provide rights concerning qualifying profiling, artificial intelligence, or automated decision-making, Bella Ora will honor those rights as required.

Individual Bella Ora brands or services that use artificial intelligence or automated systems in materially different ways may provide supplemental disclosures.

Bella Ora does not sell personal information for monetary consideration as a standalone business activity.

Bella Ora may, however, use analytics, advertising, marketing, social-media, and technology providers in ways that involve the disclosure or availability of information such as:

1. online identifiers;
2. cookie identifiers;
3. device information;
4. IP addresses;
5. website activity;
6. advertising interaction data;
7. campaign information; or
8. similar information.

Under certain privacy laws, some of these disclosures or uses may be legally defined as:

1. a "sale";
2. "sharing";
3. targeted advertising;
4. cross-context behavioral advertising; or
5. another similar regulated activity,

even where Bella Ora does not receive money in exchange for the information.

Where applicable law provides a right to opt out of those activities, Bella Ora will provide and honor the legally required mechanisms.

Bella Ora may also honor qualifying browser-based privacy preference signals where required by applicable law.

Bella Ora and its service providers may use cookies, pixels, tags, local storage, software development kits, or similar technologies for purposes such as:

1. necessary website functionality;
2. security;
3. fraud prevention;
4. remembering preferences;
5. maintaining sessions;
6. analytics;
7. understanding visitor activity;
8. measuring performance;
9. campaign attribution;
10. improving websites or services;
11. marketing; and
12. advertising where used.

Bella Ora may classify these technologies into categories such as:

1. Necessary;
2. Functional;
3. Analytics; and
4. Marketing or Advertising.

Where applicable law requires consent before nonessential technologies are used, Bella Ora will obtain the required consent.

Where legally appropriate, visitors may be provided with controls to accept, reject, or manage optional technologies.

You may also manage cookies through your browser settings. Disabling certain cookies or technologies may affect website functionality.

Bella Ora does not currently maintain a separate public Cookie Policy. Cookie and similar-technology disclosures are provided through this Privacy Policy and applicable consent or preference controls.

Certain browsers or extensions allow users to transmit privacy preference signals, including the Global Privacy Control ("GPC") signal.

Where applicable law requires Bella Ora to recognize a qualifying browser-based privacy signal, Bella Ora will honor the signal for the activities and device or browser context to which the signal legally applies.

Browser-based privacy signals generally do not communicate:

1. email marketing preferences;
2. SMS preferences;
3. telephone preferences;
4. WhatsApp preferences; or
5. brand-specific marketing preferences.

To manage those preferences, use the methods described in this Privacy Policy.

Bella Ora may create aggregated, anonymized, or de-identified information from information we lawfully maintain.

Bella Ora may use such information for purposes such as:

1. analytics;
2. benchmarking;
3. business planning;
4. product and service improvement;
5. research;
6. trend analysis;
7. performance measurement; and
8. understanding Bella Ora's businesses and audiences.

Bella Ora may retain such information as permitted by law.

Where applicable law requires de-identified information to remain de-identified, Bella Ora will not intentionally reidentify it except where legally permitted for legitimate purposes such as security, integrity testing, or compliance.

Bella Ora may disclose personal information in the circumstances described below.

Participating Bella Ora Brands

Information may be used internally across participating Bella Ora brands as described in this Policy.

Service Providers

Bella Ora may disclose information to vendors and service providers that perform functions such as:

1. website hosting;
2. cloud infrastructure;
3. database services;
4. CRM;
5. analytics;
6. communications;
7. email delivery;
8. accounting;
9. inventory management;
10. marketing support;
11. security;
12. fraud prevention;
13. customer support;
14. technical support; and
15. other operational services.

These providers may process information on Bella Ora's behalf subject to applicable contractual and legal requirements.

Independent Third Party Platforms

Some third party platforms may process information under their own privacy policies when you interact directly with them.

Examples may include social networks, external websites, communication platforms, embedded services, or other independent platforms.

Bella Ora does not control every independent use of information by those third parties.

Legal and Protective Disclosures

Bella Ora may disclose information where reasonably necessary to:

1. comply with applicable law;
2. respond to lawful legal process;
3. investigate fraud or misuse;
4. enforce agreements;
5. protect rights or property;
6. address security incidents; or
7. protect the safety of individuals or the public.

Business Transactions

Bella Ora may disclose or transfer information in connection with a proposed or completed:

1. merger;
2. acquisition;
3. financing;
4. reorganization;
5. restructuring;
6. sale of assets;
7. transfer or sale of a Bella Ora brand; or
8. similar transaction.

Such transfers remain subject to applicable law and the privacy commitments governing the information.

At Your Direction

Bella Ora may disclose information where you direct or authorize us to do so.

Bella Ora currently uses service providers with primary data infrastructure in the United States for certain core systems.

Bella Ora's current primary database infrastructure is hosted in the United States.

Some service providers or their subprocessors may nevertheless process information in other countries.

Privacy laws and protections may differ between jurisdictions.

Where applicable law requires specific safeguards for international transfers of personal information, Bella Ora will use the required safeguards.

Bella Ora may change infrastructure providers or processing locations over time as its technology and business needs evolve.

Bella Ora retains personal information based on the nature of the information, the reason it was collected, the relationship involved, and applicable legal and operational requirements.

Retention considerations may include:

1. whether a relationship remains active;
2. transaction history;
3. accounting requirements;
4. tax obligations;
5. contractual obligations;
6. fraud prevention;
7. security;
8. dispute resolution;
9. legal claims;
10. regulatory requirements;
11. marketing preferences;
12. consent records; and
13. privacy requests.

Bella Ora does not use one universal retention period for every category of information.

Information may be deleted, anonymized, or retained for a longer period where appropriate and permitted by law.

Consent and Preference History

Bella Ora may retain a historical record of privacy and communication preference changes.

This record may include:

1. the preference involved;
2. applicable brand;
3. communication channel;
4. previous state;
5. new state;
6. source of the preference;
7. date and time;
8. applicable policy or consent version;
9. opt-out or withdrawal history;
10. applicable browser preference signals; and
11. limited metadata reasonably necessary to demonstrate and honor the preference.

Bella Ora may maintain suppression records after deletion or marketing opt-out requests to prevent accidental re-enrollment.

Bella Ora uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against:

1. unauthorized access;
2. unauthorized use;
3. loss;
4. alteration;
5. misuse; and
6. unauthorized disclosure.

Safeguards are selected based on factors such as the nature of the information, the systems involved, and the risks reasonably associated with processing.

No method of internet transmission, storage, or electronic processing is completely secure.

Bella Ora cannot guarantee absolute security.

If Bella Ora experiences a security incident involving personal information, Bella Ora will investigate the incident and provide notices to affected individuals, regulators, or other parties where required by applicable law.

Not every technical or security event constitutes a legally reportable breach.

Depending on where you live and the laws applicable to Bella Ora's processing, you may have rights to:

1. request access to personal information;
2. request correction;
3. request deletion;
4. obtain a copy of certain information;
5. object to or restrict certain uses;
6. withdraw consent where processing relies on consent;
7. opt out of certain advertising activities;
8. opt out of qualifying sale or sharing;
9. opt out of targeted advertising;
10. limit certain uses of sensitive personal information where applicable;
11. exercise rights concerning qualifying profiling or automated decision-making;
12. appeal a privacy request decision; and
13. exercise other rights provided by applicable law.

Not every right applies in every jurisdiction or circumstance.

To submit a privacy request, email:

hello@bella-ora.com

with the subject line:

Privacy Request

Unless you specify otherwise, Bella Ora will treat a verified privacy request as applying across Bella Ora and participating brands covered by this Policy.

You do not need to submit a separate request to each participating brand.

You may also limit a request to a particular brand if you choose.

For requests involving access, correction, deletion, or other rights that require verification, Bella Ora may take reasonable steps to confirm that the person making the request is the individual whose information is involved.

Bella Ora may request additional information where reasonably necessary to:

1. verify identity;
2. prevent fraud;
3. protect another person's information; or
4. process the request.

Bella Ora will seek only information reasonably necessary for verification.

Simple marketing unsubscribe requests do not generally require the same identity verification process.

Where applicable law allows an authorized agent to submit a privacy request on your behalf, Bella Ora will accept qualifying authorized-agent requests.

Bella Ora may require:

1. reasonable proof that the agent has authority to act for you;
2. verification of your identity where permitted; and
3. information reasonably necessary to process the request.

Unless you limit the scope of your request, a verified deletion request will generally be treated as applying across the Bella Ora ecosystem and participating brands covered by this Policy.

Deletion rights are subject to applicable exceptions.

Bella Ora may retain information where reasonably necessary and permitted or required for purposes such as:

1. completing transactions;
2. accounting;
3. tax compliance;
4. fraud prevention;
5. security;
6. legal obligations;
7. dispute resolution;
8. exercising or defending legal claims;
9. maintaining suppression lists; and
10. honoring privacy preferences.

Where appropriate, Bella Ora may delete or suppress marketing and profiling information while retaining limited operational, transaction, legal, or suppression records.

If Bella Ora denies a privacy request, we will provide an explanation where required by applicable law.

Where a right to appeal applies, you may submit an appeal by emailing:

hello@bella-ora.com

with the subject line:

Privacy Request Appeal

Bella Ora will review and respond to the appeal in accordance with applicable requirements.

Bella Ora will not unlawfully discriminate against you for exercising privacy rights provided by applicable law.

This does not prevent Bella Ora from offering lawful differences in services, benefits, or experiences where permitted by law.

If Bella Ora establishes a program involving a financial incentive or price or service difference related to personal information, Bella Ora will provide any notice or consent required by applicable law.

Bella Ora may in the future operate Promotions, loyalty programs, membership benefits, discounts, rewards, or other programs that involve personal information.

Where a program constitutes a financial incentive, bona fide loyalty program, or similar regulated arrangement under applicable law, Bella Ora will provide the disclosures, notices, valuation information, consent mechanisms, and withdrawal rights required for that program.

Participation in an ordinary Promotion does not automatically mean the Promotion constitutes a legally regulated financial incentive program.

The Bella Ora corporate website is intended primarily for a general adult audience and is not directed to children under 13.

Individuals under 13 may encounter publicly available informational content but should not submit personal information through the Site.

Bella Ora does not knowingly collect personal information from children under 13 through the general corporate Site.

If you believe a child under 13 has provided personal information to Bella Ora, contact:

hello@bella-ora.com

Bella Ora will investigate and take appropriate action.

Individual Bella Ora brands, competitions, Promotions, or services may impose higher minimum-age requirements.

The Site may link to:

1. Bella Ora brand websites;
2. social media platforms;
3. external services;
4. partner websites;
5. media outlets; and
6. other third party services.

This Privacy Policy does not govern another operator's independent processing of information.

Review the applicable privacy notice before providing information to another service.

Bella Ora may maintain a centralized privacy and communication preference system across participating brands.

Preferences may include:

1. global Bella Ora marketing status;
2. Bella Ora corporate communications;
3. individual brand marketing preferences;
4. email preferences;
5. SMS preferences;
6. telephone preferences;
7. WhatsApp preferences;
8. targeted advertising opt-outs;
9. qualifying sale or sharing opt-outs;
10. applicable browser privacy signals; and
11. consent or withdrawal history.

A global marketing opt-out suppresses marketing across participating brands.

A later affirmative opt-in to a specific brand may reactivate marketing for that brand only.

Bella Ora intends to preserve these preferences when additional participating brands are introduced.

Adding a new brand does not automatically cancel an existing global opt-out.

Bella Ora may add new brands or DBAs to the Bella Ora ecosystem.

Where appropriate, this Policy may be updated to identify participating brands.

Existing privacy preferences and global marketing opt-outs will continue to be honored.

Adding a brand does not authorize materially different uses of personal information without appropriate disclosure and, where required, consent.

A brand with materially different data practices may provide a supplemental privacy notice.

Bella Ora may update this Privacy Policy to reflect changes in:

1. our businesses;
2. participating brands;
3. technology;
4. data practices;
5. services;
6. legal requirements; or
7. privacy practices.

Routine changes may become effective when the revised Policy is posted and the effective date is updated.

Where required by applicable law, or where a change materially affects privacy rights or prior commitments, Bella Ora will provide additional notice or obtain consent as appropriate.

Privacy Policy updates do not automatically cancel existing marketing opt-outs or other stored privacy preferences.

For questions about this Privacy Policy, privacy requests, appeals, or marketing preferences, contact:

1. Bella Ora, LLC
2. Email: hello@bella-ora.com
3. Website: www.bella-ora.com

For formal legal notices, Terms-related matters, or copyright complaints, contact:

1. legal@bella-ora.com