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EXHIBIT A

Privacy Policy

ALOHA LANI AGENCI HAWAII


Privacy Policy


ALOHA LANI AGENCI HAWAII (“ALA HAWAII”) respects your privacy and has developed this Privacy Policy (“Privacy Policy”) to demonstrate its commitment to protecting your privacy. Capitalized terms not defined herein shall have the same meanings provided to them in ALA HAWAII’s Terms of Service.


1. Information ALA HAWAII Collects.

The types of information that ALA HAWAII collects fall under two general categories: personally identifiable information (“PII”) and non-personally identifiable information (“nonPII”). PII consists of any information which can be used to specifically identify you as an individual, whereas non-PII consists of aggregate information or any information that does not reveal your identity.


2. How ALA HAWAII Collects Information.

a. Information About You. When you register or subscribe to any of ALA HAWAII’s Services, ALA HAWAII collects a wide variety of information about you.


b. Purchase Information. To process purchases, ALA HAWAII may require your name, address, phone number, email address and credit card information. Such information is used primarily to process your order of ALA HAWAII’s Services.


c. E-mails and Telephone Calls. ALA HAWAII requires an e-mail address and phone number from you when you register for ALA HAWAII’s Services. ALA HAWAII will use your e-mail for both transactional (e.g., order confirmation, renewal processing, notifying of matches) and promotional (e.g., new Service offerings, special discounts, event notifications, special thirdparty offers) purposes. If you would rather not receive promotional e-mails from ALA HAWAII, please see the section below labeled “Choice/Opt-Out”. ALA HAWAII reserves the right to send you certain communications relating to ALA HAWAII’s Services, such as service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. ALA HAWAII may also contact you by telephone or text message (including to any wireless number you may provide to ALA HAWAII) in connection with ALA HAWAII’s Services.


3. How ALA HAWAII Uses Information.

a. ALA HAWAII may use information that ALA HAWAII collects about you to:


i. deliver the Services that you have requested;


ii. manage your account and provide you with customer support;


iii. communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you;


iv. verify your eligibility and deliver prizes in connection with contests and sweepstakes;


v. enforce or exercise any rights in ALA HAWAII’s Terms of Service; vi. manage ALA HAWAII’s business; and

vii. perform functions as otherwise described to you at the time of collection.


b. Disclosure By Law. You acknowledge and agree that ALA HAWAII may disclose information you provide if ALA HAWAII is required to do so by law, at the request of a third party, or if ALA HAWAII in its sole discretion, believes that disclosure is reasonable to (1) comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law); (2) protect or defend ALA HAWAII’s, or a third party’s, rights or property; or (3) protect someone’s health or safety, such as when harm or violence against any person (including you) is threatened.


c. Disclosure to Trusted Third Parties By ALA HAWAII. ALA HAWAII may share your nonPII with third parties, but not in a manner that would reveal your identity. ALA HAWAII may share your PII, sometimes in conjunction with your non-PII, with service providers that may be associated with ALA HAWAII to perform functions on ALA HAWAII’s behalf. Your information will be treated as private and confidential by such service providers and will not be used for any other purpose than purposes that ALA HAWAII authorizes. In addition, from time to time, ALA HAWAII may share PII (such as e-mail or mailing address) about ALA HAWAII's user base with carefully selected third parties, so they can offer goods and services that ALA HAWAII believes may be of interest to ALA HAWAII users. If you do not wish to receive offers from ALA HAWAII’s trusted partners, you can change your e-mail preferences at any time by following the steps outlined in the “Choice/Opt-Out” section below.


d. Information Transferred As a Result of Sale of Business. As ALA HAWAII develop its business, ALA HAWAII may buy or sell assets and, depending on the transaction, your PII may be one of the transferred assets. In the event that ALA HAWAII is acquired by another company, your PII may be part of the assets transferred to the acquiring party. If this occurs, you will be notified if there are any material changes to the way your PII is collected or used.


e. Certain services made available via https://www.alohalaniagenci.com are delivered by third party sites and organizations. By using any product, service or functionality originating from the https://www.alohalaniagenci.com domain, you hereby acknowledge and consent that ALA HAWAII may share such information and data with any third party with whom ALA HAWAII has a contractual relationship to provide the requested product, service or functionality on behalf of https://www.alohalaniagenci.com users and customers.


4. Age Restrictions.

ALA HAWAII’s age restrictions are set forth in the Terms of Service. ALA HAWAII does not target the ALA HAWAII Site or Services to children under the age of 13, and in compliance with the Children’s Online Privacy Protection Act, any information ALA HAWAII may receive from users ALA HAWAII believes to be under the age of 13 will be purged from ALA HAWAII’s database.


5. Security.

ALA HAWAII has extensive security measures in place to protect the loss, misuse and alteration of the information stored in ALA HAWAII’s database. These measures include the use of use of industry standard secure server software (SSL) to ensure the safety of your personal information. ALA HAWAII does not store credit card or financial information. ALA HAWAII will exercise reasonable care in providing secure transmission of information between your computer and ALA HAWAII’s servers, but given that no information transmitted over the Internet can be guaranteed 100% secure, ALA HAWAII cannot ensure or warrant the security of any information transmitted to ALA HAWAII over the Internet and hence accepts no liability for any unintentional disclosure.


6. Choice/Opt-Out.

You may remove your information from ALA HAWAII’s e-mail database if you wish to opt out of receiving promotional e-mails and newsletters. To do so, please send a written request letting ALA HAWAII know which promotional e-mails you wish to opt-out of to:


ALOHA LANI AGENCI HAWAII

888 MILILANI STREET, PENTHOUSE #2

HONOLULU, HAWAII 96813


7. Updating Your Information.

To change or modify information previously submitted to ALA HAWAII, including deletion of your personal information (but ALA HAWAII may keep certain information for record keeping integrity, fraud prevention, enforcement of ALA HAWAII’s terms, or to the extent it relates to a pending dispute), you can send a written request to the postal address listed above, providing ALA HAWAII with your account information and letting ALA HAWAII know which information you wish to update.


8. Acceptance of Privacy Policy.

Your use of ALA HAWAII’s Site and Services, including any dispute concerning privacy, is subject to this Privacy Policy and the applicable Terms of Service. BY USING ALA HAWAII’S SITE, YOU ARE ACCEPTING THE PRACTICES SET OUT IN THIS PRIVACY POLICY AND THE APPLICABLE TERMS OF SERVICE. If ALA HAWAII decides to change ALA HAWAII’s privacy policy, ALA HAWAII will post those changes to this Privacy Policy page and any other places ALA HAWAII deems appropriate so that you are aware of what information ALA HAWAII collects, how ALA HAWAII uses it, and under what circumstances, if any, ALA HAWAII discloses it. ALA HAWAII reserves the right to modify this Privacy Policy at any time, so please review it frequently. If ALA HAWAII makes material changes to this policy, ALA HAWAII will notify you here, or by other means, such as e-mail, at ALA HAWAII’s discretion. Your continued use of any portion of ALA HAWAII’s site following posting of an updated Privacy Policy will constitute your acceptance of the changes.


Effective Date. This Privacy Policy was last revised on February 23, 2015.

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