Privacy Policy

Introduction

Thank you for accessing the Irenenakamura.com website operated by Irene Nakamura doing business as Irene Nakamura (“Irene,” “we,” “our,” or “us”). We respect your privacy and want to protect your personal information. This Privacy Policy governs the Irenenakamura.com website and its subdomains (the “Site”), portals, applications, products, services, events, and any interactive features, applications, and/or other services that reference this Privacy Policy. This Privacy Policy also applies to Personal Information we may collect from you on our website, via telephone calls with our office, through online payments, or in any other instance when you contact us. This Privacy Policy does not apply to any products, services, websites, or content that are offered by third parties (“Third Party Services”), which are governed by their respective privacy policies.

Since we are a fairly small company, we don’t meet the thresholds to require a lot of fancy language about privacy (some new state privacy laws do not apply to us). But we do want to tell you what information we collect from you, why we collect it, how we use it, under what circumstances we may share it, how we protect it, and how you can modify the use of your information.

This Privacy Policy describes what information we collect from you, why we collect it, how we use it, under what circumstances we may share it with third parties, and how we protect that information. To the extent we provide you notice on our Site of different or additional privacy policies or practices (e.g., at the point of collection of your information), those additional terms shall govern such data collection and use. If you voluntarily provide your information in the course of using or interacting with our Site, purchasing our products, or using our Services, we will take that as your agreement to our collection, use, and disclosure of your information as set forth in this Privacy Policy.

In addition, please review the Site’s Terms of Use, which govern your use of the Site. By using our Site, you consent to our Privacy Policy and agree to our Terms of Use.

Table of Contents

Contents

1. What Information We Collect

2. Use of Cookies and other Tracking Technologies

3. Why We Collect Information

4. When We Disclose Information

5. Your Choices About the Information We Collect

6. Controlling Cookies

7. Your California Privacy Rights

8. Your Privacy Rights under Other US State Laws

9. Updating Personal Information

10. Links

11. Security

12. Questions / Changes in Privacy Policy

1. What Information We Collect

Information You Provide to Us

In connection with speaking and consulting services we provide (the “Services”), we may ask you to provide us with (i) your first and last name, email address, home or business address, other shipping or billing addresses, telephone number, mobile number, your purchase/order history, your birthdate, or other information that could reasonably be used to identify you personally or identify your household (hereinafter, “Personal Information”); and/or (ii) demographic information, such as your country, state, or county of residence or business operation (“Demographic Information”). We may collect this information when you:

Register and/or order products or Services on our Site;

Login to obtain copies of products or Services ordered from Irene Nakamura;

Contact us regarding a question, concern, or inquiry, such as when you make inquiries concerning our Site, products and/or Services;

Sign up or request to be placed on our mailing and/or email marketing lists; and/or

Otherwise interact with the Site or our staff.

Depending on the services you use, you may also provide to us information about yourself, if you’re an individual; your clients; your employer; your counsel; your employees; employees of your clients or customers; employees of parties adverse to you or your clients; or employees of third parties who may be involved in litigation with you or your clients.

Your decision to provide us with information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all of the Site’s features or our Services, including ordering products, submitting inquiries, or signing up for newsletters or marketing lists.

Irene further recognizes the importance of children’s safety and privacy. The Site is not designed to attract children and is not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children. Minors under the age of 18 may use the Site only under the supervision of a parent or legal guardian who agrees to be bound by the Site’s Terms of Use.

General Browsing

In addition to information that you choose to submit to us, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include:

your IP address, UDID or other unique identifier (“Device Identifier”);

your Device functionality (including browser, operating system, hardware, mobile network information);

the areas within our Site that you visit and your activities there, including remembering you and your preferences;

your Device location;

your Device characteristics; and

certain other Device data, including the time of day you visit our Site.

2. Use of Cookies and other Tracking Technologies

We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site, include, without limitation, the following (and subsequent technology and methods later developed):

• Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage.

• Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.

• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.

• ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.

• Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

• Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

We may use Tracking Technologies for a variety of purposes, including:

To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality or to allow you to make use of shopping cart or payment functionality;

To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;

To offer you enhanced functionality when accessing the Site, including identifying you when you sign into our Site or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and

To deliver content relevant to your interests on our Site and third party sites based on how you interact with our advertisements and/or content.

Information We Collect When You Interact with Third-Party Sites

The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we may provide links on the Site to facilitate sending a communication from the Site or we may use third parties to facilitate emails or postings to social media. We may use third parties to deliver products to you. We also may provide links to allow third parties to process credit card and/or electronic payments. These third parties may retain any information used or provided in any such communications or activities and these third parties’ practices are not subject to our Privacy Policy. Irene may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Site.

3. Why We Collect Information

We may use your Personal Information, Demographic Information, or Usage Information for various purposes, including:

Providing speaking and consulting services;

Maintaining your account;

Processing your order and providing you with customer service, including responding to your inquiries regarding our products and Services and/or communicating with you regarding orders and deliveries;

Sending you marketing information about Irene and our affiliated entities;

Sending you email communications such as electronic newsletters about our products, Services, events, and promotions;

Improving the effectiveness of our Site, marketing endeavors, and product and service offerings;

Identifying your product and service preferences, providing personalized content and ads and informing you of new or additional information, products and services that may be of interest to you;

Helping us address problems with and improve our Site and our products and services;

Providing mobile marketing messages and other communications and messages;

Protecting the security and integrity of the Site;

For internal business purposes; and

For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

4. When We Disclose Information

We may share non-Personal Information, such as aggregated user statistics and your Device Identifiers with third parties along with data related to you and your activities. Also, we may share your information, including your Personal Information, with third parties, such as companies with whom we have marketing or other relationships, for the third parties’ direct marketing purposes. (If you are a California resident, you have the right to request additional information and so please see the Section entitled “Your California Privacy Rights” below about these rights.) In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described in this Privacy Policy. Examples of when Irene may share your information include as follows:

Third Parties Providing Services to Irene. We may use Third-Party Service providers to perform certain services on behalf of us or the Site, such as: (i) shipping products and ensure delivery; (ii) processing credit cards and/or electronic payments; (iii) assisting us in Site operations; (iv) managing a database of customer information; (v) hosting the Site; (vi) designing and/or operating the Site’s features; (vii) tracking the Site’s activities and analytics; (viii) enabling us to send you special offers or perform other administrative services; and (ix) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information to carry out the services they are performing for you or for us. Those vendors may have additional or different privacy policies and/or Terms of Use. You should be sure that you read and agree to those policies and Terms.

To Protect the Rights of Irene and Others. To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Irene or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

Affiliates and Business Transfer. We may share your information with our parent, subsidiaries and affiliates. As part of this sharing of information with our parent, subsidiaries and affiliates, this means that once you provide us with information, any one of our related entities may use your information including for marketing purposes, pursuant to the terms of this Privacy Policy. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site and/or our Services; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during any due diligence process.

5. Your Choices About the Information We Collect

Communication Preferences

If you would prefer that we not share your name and mailing address with third parties (other than with our affiliates) to receive promotional offers, you have the option to opt out of such sharing. To do so, please email us at irene@irenenakamura.com. Your choice will not affect our ability to share information in the other ways described in this Privacy Policy.

If you do not wish to receive e-mails about special offers, events, and other promotions from us, email us at irene@irenenakamura.com to opt out, or if you do not wish to receive other marketing materials by regular mail from us.

Do Not Track

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

Controlling Cookies

We may use Tracking Technologies to address your preferences on our Site, or to report how you used the Site. You can set your web browser to alert you when a cookie is being used. You can also get information on the duration of the cookie and what server your data is being returned to. You then can accept or reject the cookie. Additionally, you can set your browser to refuse all cookies or accept only cookies returned to the originating servers.

Some services may not function or may have more limited functionality if your web browser does not accept cookies. However, you can allow cookies from specific websites by making them ‘trusted websites’ in your web browser.

You can opt in or out of cookies at any time – except strictly necessary cookies (these are used to help make our website work efficiently). If you wish to restrict or block the cookies set by any website, you can do this through the web browser settings for each web browser you use, on each device you use to access the internet. You may “clear” all cookies to force our cookie preferences panel to restart so that you may change your cookie preferences at any time. Currently, you cannot synchronize your settings between your browsers and devices (e.g., your computer and your smartphone), so you must manage your cookies on each browser, on each device.

Information on controlling and deleting cookies, including on a wide variety of browsers, is also available at allaboutcookies.org. Some of the more popular browsers (and links to manage your cookies on each) are:

Microsoft Edge

Firefox

Safari

Google Chrome

If you do not wish to accept cookies from one of our emails, you can choose not to download any images or click on any links. You can also set your browser to restrict cookies or to reject them entirely. These settings will apply to all cookies, whether included on websites or in emails. Depending on your email or browser settings, cookies in an email may sometimes be automatically accepted (for example, when you’ve added an email address to your address book or safe senders list). For more information, refer to your email browser or device instructions.

Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the particular website you are viewing (e.g., contextually based ads) or ads that are not targeted at you which may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out, your opt-out may not be effective.

California residents have additional options to limit the sharing of their Personal Information, as set forth below in the Your California Privacy Rights section.

6. Your California Privacy Rights

This section of the Privacy Policy applies solely to California residents. We adopt this Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section. Current and prior employees, job applicants and independent contractors may have additional or different disclosures available to them, as set forth below.

California residents have the following rights:

To know the categories of personal information being collected about you, the purposes for which the categories of information are collected or used, and whether that information is sold or shared;

To know if sensitive personal information is being collected about you, the categories of sensitive personal information being collected, the purposes for which the categories of sensitive personal information are collected or used, and whether the sensitive personal information is sold or shared;

To know the length of time we intend to retain each category of personal information;

To know whether your personal information is sold or disclosed and to whom;

To access your personal information;

To delete the information you have provided to us, with certain exceptions;

To correct your personal information;

To limit the use of your sensitive personal information;

To reject automated decision making and profiling;

To access information about automated decision making;

To opt out of the sale of personal information; and

Not to be discriminated against, even if you exercise your privacy rights.


The earlier sections in this Privacy Policy describe in detail what categories of information we collect and the purposes for which we use that information.

Request For Information, Correction, or Deletion

California consumers have the right to request, under certain circumstances, that a business that collects personal information about the consumer disclose to the consumer the information listed below for the preceding 12 months:

The categories of Personal Information we have collected from you;

The categories of sources from which we collected the Personal Information;

The business purpose we have for collecting your Personal Information;

The specific pieces of Personal Information we have collected about you.

The categories of Personal Information that we have disclosed for a business purpose, or if we have not disclosed that information for a business purpose;

The categories of Personal Information that we have sold, or if we have not sold the Personal Information;

The categories of third parties to whom the Personal Information was disclosed for a business purpose or sold;

The business purpose we have for disclosing or selling that Personal Information; and

The categories of Sensitive Personal Information we have collected, and whether such information is sold or shared, except for such information that is collected or processed without the purpose of inferring characteristics about you.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You also have the right to request that we correct or delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

As permitted by the CCPA/CPRA, if you request deletion of Personal Information that we have collected about you, we, our service providers, and our contractors may be unable to comply with such a request if your Personal Information is necessary to:

Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you;

Prevent, detect, and investigate security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

Debug to identify and repair errors that impair existing intended functionality;

Exercise free speech, ensure the right of another Consumer to exercise his or her right of free speech, or exercise another right provided for by law;

Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with section 1546) of Title 12 of Part 2 of the Penal Code;

Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of that information is likely to render impossible or seriously impair the achievement to such research, if you have provided informed consent;

Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

Comply with a legal obligation; or

Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Do Not Sell or Share My Personal information

As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. We do not sell your Personal Information at this time.

Right to Limit Use of Sensitive Personal Information

California consumers have the right to limit the use of each type of Sensitive Personal Information (“SPI”) for each purpose with each type of third-party partner. Consumers can revoke this permission at any time. Please note that we only keep SPI for the transaction for which it is required. We do not provide your Sensitive Personal Information to any third parties other than those service providers that are necessary for us to provide our Services to our employees. We do not share your SPI for cross-contextual behavioral advertising or for the purpose of inferring characteristics about you.

Right not to be Discriminated Against

We will not discriminate against you for exercising any of your rights under the CCPA or CPRA. Unless permitted by California law, we will not:

Deny you goods or services;

Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

Provide you a different level or quality of goods or services; or

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, as permitted by California law, we may offer you certain financial incentives that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to the value of your Personal Information, for instance, if you sign up for a newsletter with us, we may provide you with discounts for future products or Services. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Third Party Marketing

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. We do not provide your Personal Information to third parties for their own direct marketing purposes.

Personal Information We Collect About California Consumers

In compliance with California law, we provide the following information about our collection of certain types of personal information about you during your relationship with us, as stated above. In particular, our Site has collected the following categories of Personal Information from consumers within the last twelve (12) months of the Effective Date of this Privacy Policy:

For job applicants, current and past employees or contractors, we use your Personal Information for the purposes stated below:

For Job Applicants:

To recruit employees, including evaluation of marketing and job offering services, website traffic, and referral sources;

To process your application for employment;

To conduct employment-related background screening and/or reference checks;

To send you correspondence and information relating to your application or your employment with us;

To verify your identity, citizenship, or legal right to work for the Company, or to assist or cooperate with obtaining relevant immigration documents;

To verify your educational background and/or degrees, certifications, or qualifications for the position you apply for;

To verify your prior employment;

To offer you employment with Company;

For testing, evaluation and/or reporting metrics, including but not limited to aggregating or anonymizing such information for workforce analytics, data analytics, and benchmarking;

To comply with applicable law or regulatory requirements, including legal requirements under state and federal law, law enforcement investigations or inquiries, as well as internal company reporting obligations, such as diversity, equity and inclusion initiatives and/or Equal Employment Opportunity Act reporting obligations;

To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for such activity;

For quality assurance purposes, including call monitoring or customer service, and debugging to identify and repair errors that impair existing intended functionality;

For auditing related to a current interaction with the applicant or employee and concurrent transactions, including, but not limited to, counting impressions to unique visitors, verifying positioning and quality of impressions, and auditing compliance with this and other standards;

To analyze the effectiveness of placement of job listings and job descriptions;

For fraud prevention; and

For internal research for technological development and demonstration.

For Employees, Contractors, and Past Employees/Contractors:

All of the above, plus:

To track time and attendance;

To administer employee benefits, such as medical, dental, and/or retirement benefits, including the recording and processing of eligibility of dependents and beneficiaries, absence and leave monitoring, insurance and accident management, and rewards or discount programs offered to employees;

To provide healthcare-related services, such as accommodations and/or services based on eligibility (e.g., disability, worker’s compensation, medical condition);

To provide payroll, invoice, and tax services, including reimbursement for expenses, salary administration, payroll management, payment of expenses, payment of state and/or federal income taxes (if applicable), social security and unemployment taxes, and to administer other compensation- related payments, including bonuses and equity, if applicable;

To conduct performance-related reviews, including performance appraisals, professional development, career planning, skills monitoring, job moves, promotions and staff re-structuring;

To ensure compliance, training, examination and other requirements (e.g., workplace safety, etc.) are met with applicable regulatory bodies or governing agencies;

To provide employees with other employment-related services, such as handling of employees’ claims, travel for the Company, or administration of separation from employment;

To assist you in case of an emergency, including maintaining contact information for you, your partner or spouse, and/or your dependents in case of personal or business emergency;

To maintain the safety and security of our employees, contractors, visitors and others, including maintenance of security on Company websites, apps, intranets and/or extranets (such as monitoring email and internet access, and ensuring secure network access and data integrity), maintenance of physical security (including controlled entry to Company worksites, monitoring of worksite locations, including using location monitoring for keys, key fob or key card entry to Company property or parking areas, and ensuring that employees, contractors and visitors comply with all applicable safety regulations;

In connection with audiovisual surveillance of public spaces;

For the tracking of Company-owned or Company-leased vehicles, computers, equipment, and devices, including, but not limited to, remote deletion of Company data on business or personal devices;

For verification of proper use of Company resources;

To facilitate a better working environment;

To maintain commercial insurance policies and overages, including for workers’ compensation and other liability insurance; and

For other purposes stated at or before the time of the collection of the information.

Further, please note that under the CPRA, we may use your employee or applicant information for Company business or other notified purposes, provided that the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or processed.

Exercising Your California Privacy Rights

You or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information, if applicable, by contacting us as follows:

• Email Address: irene@irenenakamura.com

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

7. Your Privacy Rights under Other US State Laws

If you are a resident of Colorado, Connecticut or Virginia, you may have the right, upon a verified request, to:

To confirm whether a controller is processing your personal data and to access such personal data;

To correct inaccuracies in your personal data;

To delete your personal data;

To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;

To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To exercise these rights, you or your authorized agent may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by contacting us using the information in the Questions/Changes in Privacy Policy section below.

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency in order to obtain the information. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident of Colorado, Connecticut or Virginia. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

While we want to comply with the requirements of these laws, we are a small company and do not currently meet the qualification thresholds in these states.

Right to Opt Out Under Applicable State Laws

Residents of Colorado, Connecticut, and Virginia have the right to opt out of the sale of their Personal Information and targeted advertising.

California residents may have additional rights, as shown in the “Your California Privacy Rights” section above.

Opt-Out Preference Signals

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

Appeals of Our Decisions

In some states, you may appeal to us if we refuse to take action on your exercise of certain choices described above. To appeal such a refusal, please contact us using the information in the Questions/Changes in Privacy Policy section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. If your appeal is denied, residents of certain states can contact their attorney general as follows:

Virginia Attorney General

Colorado Attorney General

Connecticut Attorney General

8. Visitors to the Site Outside of the United States

If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Privacy Policy.

9. Updating Personal Information

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us at irene@irenenakamura.com.

If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons, such as a legitimate business reason.

10. Links

For your convenience, the Site may contain links to other websites. Irene is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site should be deemed to imply that Irene endorses or has any affiliation with the links.

11. Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you provide us with your information at your own risk. If you must transmit confidential information related to a matter we are handling for you, please contact us for instructions for a secure file transfer protocol.

12. Questions / Changes in Privacy Policy

If you have questions or concerns with respect to our Privacy Policy, you may contact us at irene@irenenakamura.com. We may elect to change or amend our Privacy Policy; in such event, we will post the policy changes in our Privacy Policy on the Site, and they will become effective on the date posted. If you are concerned about how your personal information is used, please visit our Site often for this and other important announcements and updates.

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