SECURITY & PRIVACY

Thank you for visiting www.adrimillerheckman.com and www.femxadvisor.com (our “Website”), which is owned and operated by Adri Miller Consulting, LLC.

This privacy policy explains our information and data processing practices, as well as the choices you can make about the way your personal information or personally identifiable information (“PII”) is collected in our stores, on our social media platforms and via our Website, as well as the manner in which we will use your information.

By submitting your PII, you are agreeing that we may collect, store, use, disclose and destroy it in accordance with this policy. In this policy, we refer to the companies in our corporate group as “femX”, “we”, or “us”. We value every customer, prospective employee and employee and want you to trust our business and privacy practices. If you have any questions about the content of this policy, we encourage you to contact us as outlined below.

PERSONAL INFORMATION WE COLLECT FROM YOU

For purposes of this policy “personal information” / “personally identifiable information” / “PII” means any information by which you can be identified, including your name, address, telephone number, email address, billing and account information, credit or debit card information, and other information incidental to providing goods or services.

We collect PII from you only when you voluntarily provide us with this information. Some examples of the manner in which we collect your PII include when you place an order through our Website or in our stores, register your femX product after purchase, register an online account on the Website, program reminders, or address book entries, enter a contest, take a survey, contact us with a comment or question, request a catalog, sign up either online or at an event to receive emails or marketing communication about our femX products and services, request to receive investor alerts, or apply for a job with us. Some of these methods of data collection are further outlined below.

A. WEBSITE REGISTRATION

To register on our Website, you must complete the registration process by providing PII, such as your name, address, email, telephone number or mobile phone number, as well as information relating to what you would like to receive from us. If you choose to register, you will be asked to choose a user name and password. You have the right to unsubscribe at any time and the manner in which this can be done is explained further once you have accessed your account.

B. SHOPPING WITH femX

If you make a purchase from our Websites, we obtain PII from you relating to the order. This may be done either online or in-store. The PII collected by us varies depending on the location and manner of your purchase, but it will generally include your billing, shipping and payment information. In addition to using this PII to fulfill your order, we also retain order information to better serve you on future purchases. Should you opt in to receive marketing communication from us we may also use this PII to contact you in connection with other femX products or services that we believe may be of interest to you. Again, you may unsubscribe from marketing communication at any time. If you receive your marketing by email, each email will have a single click unsubscribe button at the bottom.

C. EMPLOYMENT APPLICATIONS

If you apply for a job with us, PII requested may include your qualifications for the position, your education, applicable licenses or certifications, prior job history, references, and any other information that you may choose to include about yourself. If you are accepted for employment, we will, of course, collect other relevant PII from you and include it in your personnel file with that collected during the application process. The PII that will be collected for purposes of your employment includes your Social Security number.

D. MARKETING COMMUNICATIONS

If you choose to sign up for email communications either while browsing the Website or during one of your store visits, you must submit certain basic information during the registration process, this will include your name and email address. This PII is used to send you email marketing communications and to ensure that we can provide you with appropriate customer care and respond to your inquiries.

E. SURVEYS

While visiting certain portions of the Website, you may be given the opportunity to provide feedback regarding various femX products. In order to fully participate in these portions of the Website, you will be asked to provide your name and email address, as well as a created online username which will be publicly linked to your product ratings, questions, answers and other comments. femX retains this additional PII, if provided, and uses it to help us better understand and respond to the collective feedback we receive. We may also invite you to participate in a survey or poll such as providing feedback on our Website site content, services, or products. Your responses will be anonymous unless you choose to provide your contact details so that we can provide you with additional information regarding the survey or poll.

For any PII that we collect, we becomes the owner and data controller of that information.

F. COOKIES AND WEB TRACKING TECHNIQUES

We use “cookies” on our Website to help us analyze web traffic and evaluate and improve the content or functions of our Website. A cookie is a small text file which is sent by a website, accepted by a web browser and then placed onto your computer’s hard drive. The information collected from these cookies lets us know that you visited our site in the past, and helps you avoid having to re-enter information on each visit in order to use some of our online functionality. Cookies also help us analyze use of our site, and better aggregate useful information when site users provide feedback about our site or products. You can set your browser to refuse cookies from our Website. This will provide you with more control over the acceptance of cookies on your hard drive. However, it is possible that some portions of the Website will not function properly or may perform more slowly if you choose to reject cookies. By using our Website and not disabling cookies, you consent to allowing their use for the described purposes. We may also collect information about your method of access such as your operating system and the type of browser that you use. We may use access method information along with information about site searches you run to serve you personalized content using third party vendors.

We use third party advertising companies to serve advertisements on other sites you may visit. To accomplish this, these companies may employ anonymous cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness and understand your visits to our Website and other web sites. These selected companies also provide this information to us which we use for marketing purposes.

Do Not Track (DNT)

We do not respond to or honor “Do Not Track” (also known as DNT) signals or similar mechanisms transmitted by web browsers. To learn more about browser tracking signals and DNT, please visit http://allaboutdnt.org.

G. SOCIAL MEDIA PLATFORMS

When you visit one of our pages on a third party social networking platform such as Facebook, Pinterest, YouTube or Twitter, you may encounter social media plugins such as Facebook “Like”, Tweets, Pinterest “Pin” buttons, etc. When you use these social networking platforms and plugins, your username and password for the services and other information available about you or collected from you on these services may be shared with us.

When you use social networking platforms and plugins, you share your PII with the operators of those platforms and their privacy policy and applicable terms of use apply to the use and disclosure of such PII.

femX’s USE OF YOUR PERSONAL INFORMATION

We use PII collected from you for the following purposes:

• for the specific purpose for which it was provided by you;
• to improve the content, appearance and utility of our website or stores;
• to understand your needs and preferences in relation to femX;
• to develop, market, sell or provide products and services;
• to conduct surveys, research and evaluations;
• to manage and develop our business and operations, administer accounts, and collect and process payments;
• to detect and protect us and other third parties against negligence, fraud, theft and other illegal activities;
• as permitted by, and to comply with, any legal or regulatory requirements, process or provisions; and
• if you submit a resume, we may use the information you provide solely for the purpose of evaluating you as a candidate for employment and to contact you about prospective employment.

We may combine information you provide to us from multiple sources and with information from third parties including demographic or public information.

femX’S SHARING OF YOUR PERSONAL INFORMATION

We may share your PII with our subsidiaries or affiliated companies, including those located in other countries. We also may share your PII with selected third parties who provide services to us, including to process payments, provide electronic online investor information, monitor Website activity, serve Website content, help to maintain our customer database, administer emails, surveys, or contests and administer and maintain employment application information. Such third parties may have access to, store and process your PII to provide services on our behalf, which may occur in the United States or in countries outside of the United States. Our service providers are not authorized to use your PII for any purpose other than to provide the services that femX has contracted from them. We also must always reserve the right to disclose PII about you as required by law, in response to legal process including law enforcement requests, and where needed to protect the safety, property, or legal rights of the Company or its affiliates or third parties.

Occasionally we may provide a link to a third party website, which is not owned or operated by femX. If you elect to provide your PII on that third party website, this information will be subject to that third party website’s privacy policy and security practices. We are not responsible or liable for any content presented by or contained on any independent website, including, but not limited to, any advertising claims or marketing practices. We also are not responsible or liable for any privacy or security policies of these third party sites.

In the unlikely event that femX or substantially all of its assets are acquired by another company, or due to any merger, reorganization or liquidation, your PII may be one of the transferred assets, however it will remain subject to any pre-existing privacy policy unless you consent otherwise.

femX is primarily intended for residents of the U.S. If you happen to live in another country and use our website, any data collected about you with respect to your use of our Website will be transferred to the U.S. Please note that there may be different standards that apply to how your data is used and protected than the standards in place in your country.

femX never sells any PII that you provide to us for use by any third party. However, from time to time, we may provide aggregate (statistical) anonymized information about our customers, sales, online traffic patterns and related information to reputable third parties who help us improve our business and services. These statistics do not include PII.

PROMOTIONS AND THIRD PARTIES

From time to time, femX may run promotions offering special deals, coupons, discounts, chances to win contests, and other prizes. These promotions may necessitate the involvement of third parties. In order to participate in these promotions, femX may require certain basic information about you, such as your name, email address, physical address, and age. This and other required information may be stored by femX in order to help us better understand how we can design and market our products for you and others. This information may also be shared with third-party promotional partners involved in the specific promotion for which you signed-up. Unless otherwise stated in the terms and conditions of the promotion, your participation is not an automatic opt-in to receive marketing materials from femX.

SAFE HARBOR AND PERSONAL INFORMATION TRANSFERS

femX complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. However, on October 6, 2015, the European Court of Justice (ECJ) issued its decision in the case of Maximillian Schrems v. Data Protection Commissioner which found the U.S.-EU Safe Harbor Framework to be invalid, affecting many companies that need to transfer personal data from EU member states to the United States and to other non-EU/EEA countries. While the Company continues to adhere to the Safe Harbor Principles and has certified its compliance, in light of the suspension of the U.S.-EU Safe Harbor Framework and U.S.-Swiss Safe Harbor Framework, femX has evaluated various other data transfer mechanisms and has decided to authorize these personal data transfers using European Commission-approved Standard Contractual Clauses (also referred to as Model Contracts). To learn more about the Safe Harbor program, and to view the Company’s certification, please visit http://www.export.gov/safeharbor.

YOUR INFORMATION — YOUR RIGHTS

A. RIGHT TO UNSUBSCRIBE

You have the right to unsubscribe from receiving marketing emails from femX, as well as the right to unsubscribe from any of the programs that we offer. You can unsubscribe by clicking on the unsubscribe link at the bottom of any femX email that you receive, or by emailing us at info@adrimillerheckman.com with your request, or by calling customer care at 860.470.3155.

Please note that if you already have requested products or services when you decide to withdraw consent, there may be a short period of time for us to update your preferences and ensure that we honor your request.

B. UPDATE, MODIFY OR CORRECT YOUR INFORMATION

The accuracy, integrity and security of your PII is very important and femX takes reasonable steps to ensure that these priorities are addressed. We encourage you to contact us to update or correct your PII if it changes or if you believe that any information that we have collected about you is inaccurate. Consistent with legal requirements and limitations, femX also permits you to obtain a copy of PII that we hold about you. To do so, please use the contact information in the Questions or Concerns section of this privacy policy.

Please note that we will likely require additional information from you in order to honor your request, such as to ensure proper authentication or to verify the business branch of femX to which the information was provided.

C. SAFEGUARDING YOUR PERSONAL INFORMATION

femX follows applicable laws and requirements to protect and safeguard your PII. We have adopted physical, electronic, and administrative safeguards that are designed to protect your PII, by reducing the risk of loss, misuse, alteration, theft, unauthorized access, or unauthorized disclosure.

For example, when you provide place on order on our Website, we use Secure Socket Layer (SSL) technology, an encryption tool that provides security while transmitting information over the Internet. We also use firewall technology, password controls, and other technological and procedural safeguards in respect of your online interactions with femX.

We evaluate our privacy safeguards on an ongoing basis to help minimize risks from new security threats as they become known. Although we have implemented the above security measures, we note that 100% guaranteed security is not possible for any company.

D. CALIFORNIA RESIDENTS

Under California law, if you are a resident of California, you are entitled once per year to request and obtain certain information regarding the Company’s disclosure, if any, of your personal information to third parties for their direct marketing purposes during the immediately prior calendar year. To make such a request, please send an e-mail to info@adrimillerheckman.com with your full name, e-mail address, and postal address in your message. In response to your request, the Company will provide you with a notice describing the cost-free means to opt-out of our sharing your personal information with third parties with whom the Company does not share the same brand name, if the third party will use it for their direct marketing purposes.

QUESTIONS OR CONCERNS

As stated above, we welcome your queries concerning the protection and correction of your personal data. If you have any questions or concerns about any of femX’s practices in respect of PII please do contact us at:

Email: info@adrimillerheckman.com

femX Customer Care
860.470.3155
M-F 10 am – 4 pm EST

When contacting us, please be sure to provide us with your a correct contact information in order to be sure we handle your request correctly.

Following any incidence of communication from you to femX some of your PII may be retained for a period of time for financial, legal or technical reasons.

OUR COMMITMENT TO CHILDREN’S PRIVACY

This Website is not intended for use by children under the age of 13. femX adheres to the Children’s Online Privacy Protection Act and we do not knowingly register or otherwise collect PII from any child under the age of 13 without the prior verifiable consent of the child’s parent or guardian.

CHANGES TO THIS PRIVACY POLICY

The Company reserves the right, at its discretion, to change, modify, add, or remove portions of this privacy policy at any time. You should check this page periodically for changes. Your continued use of the Website following the posting of changes to this privacy policy will be considered your consent to those changes .In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, to the extent we have your email address, we may notify you by email.