LEGAL

 At Ella (“Ella”, “we”, “us” or “our” in this Policy), we are committed to respecting your privacy and protecting the Personal Data (as defined below) that we obtain and hold about you and others. This privacy policy (“Policy”) explains how we will process the Personal Data relating to you that you provide to us when you visit our Site (as defined in our Terms Of Use, found at EllaPads.com/terms hereinafter the “Terms”), namely the website at EllaPads.co or in relation to any query or communications that you may send to us, or that we may collect from others about you when you visit our Site. If there are any practices in this Policy that you do not consent to, please discontinue use of our Site.

1. Introduction and General Terms. The Site is operated by Ella Pads, a company registered in the State of New Jersey, United States of America. The Site allows customers to view and purchase feminine products, among other things (“Services”). Where we decide the purpose or means for the processing of the Personal Data that you provide when using our Site, we are the “data controller” for the purposes of the European General Data Protection Regulation 2016 (“GDPR”). Our Site may contain hyperlinks to third party websites. These websites operate fully independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources. The appearance of such links on our Site is not an endorsement. Should you use any of these websites, such use is at your own risk and we would recommend that you review their respective privacy policies and our Terms.

2. What Information Will We Collect About You? Information voluntarily provided: You may give us information about you by filling in forms when using our Services, setting up an account, signing up to our newsletter, interacting on the Site, or contacting us with e-mail and other similar inquiries. Such information can include: Identity and contact Data: We collect your name, address, email address, and telephone number. Purchase Data: We collect data necessary to process your payment if you make purchases including feminine products that you have requested or purchased and credit card information. All payment data is stored by the applicable payment providers detailed herein. Analytics Data: Our web host and third-party service providers automatically collect certain data about you as you use the Site or Services (consistent with our Analytics & Cookie Policy described below). Other information: We collect your contributions, text, writings, reviews, responses, comments, suggestions, and other material that you voluntarily provide to us or with your consent. Personal Data We Collect Through Our Social Media Pages: We have pages on social media sites like Facebook, Instagram, Twitter, Snapchat, Pinterest, YouTube and TikTok @Ella.Pads. When you interact with our Social Media Pages, we will collect personal data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages. The foregoing shall be referred to herein as “Personal Data”.

3. How We Use Your Personal Data Providing the Services to you as a prospective or existing customer. We may legally use and retain your Personal Data where we need to perform the contract we are about to enter into or have entered into with you, such as: Setting up your account on the Site (or Site Account, as defined in the Terms); Processing purchases (including any shipping details for delivery of the feminine products) under our terms of sale; To administer, operate, maintain, and improve the Site and Services by receiving and responding to your orders and service requests, marketing to you, and notifying you when our Site is undergoing maintenance or changing its Terms or Privacy Policy; To comply with legal obligations and protect our rights In order for you to purchase products via our Site, we currently use the third-party payment provider Shopify Payments (a PCI Service Provider Level 1 certified platform) to collect, store and process payment information from you, including your name, email address, credit card number and bank account details. Our servers will not collect or have access to your payment details. Any purchases you make via the Site will also be governed by the Payment Provider’s terms and conditions and/or privacy policies. We may contact you via email to remind you about products you left in your shopping basket that you may want to purchase. We will do this pursuant to our legitimate interests in promoting our business. If you do not wish to be contacted via email please let us know by clicking unsubscribe at the bottom of any email that you receive.Contacting Us (Your Enquiries). If you contact us via our Site, to make an enquiry or otherwise, in certain situations we will ask you to provide a limited amount of Personal Data about yourself, such as your name, email address, and your message or enquiry in the free text box. We will use this information to respond to your enquiries, for example: In line with the legitimate interest we have in promoting our business, we will process your enquiries to reply to your query, including providing you with information about the Services we offer and keeping track of your purchase history. We may also process enquiries to take steps you ask of us with a view to entering into an agreement to provide you with our Services. You are under no obligation to provide us with any details, but if you choose to not provide us with relevant information, we may not be able to respond and/or provide the assistance that you request.Mailing List. If you ask to be added to our mailing list by subscribing to our newsletter, we will keep you updated with information on news, offers, updates on new feminine and other products and events via email. We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email. In line with the legitimate interest we have in promoting our business, we will use the email address you give us via our Site to provide you with this information. If you would like to be removed from that list, please let us know by clicking unsubscribe at the bottom of any marketing email that you receive. After you unsubscribe, you will be removed from our mailing list within a reasonable time. There may also be circumstances where we will ask you for your prior consent in respect of our use of your Personal Data or where we may rely on an alternative lawful basis to process your Personal Data in which case you will be notified at the time.How You Use our Site (Analytics & Cookie Policy).

This section applies to all information collected through the Site or Services, including the technologies we and third parties with whom we partner, use for automatic data collection. Our Site uses cookies and other mechanisms to collect and log analytical information, to help analyze how visitors use the Site and to compile statistical reports on Site activity. This processing is crucial to the running of our online business. This information is not used to develop a personal profile of you. We use Google Analytics. When you visit our Site, these analytics service providers may collect the following data, which will be anonymized and aggregated before reporting back to us: Your IP address; Demographic information including your age, gender, location, and language preferences; Your device or browser information and other log data; number of visitors to our Site; pages visited while at the Site and time spent per page; page interaction information, such as scrolling, clicks and browsing methods; peak hours of visit; websites where visitors have come from and where they go afterwards; page response times and any download errors; and other technical information relating to end user device, such as IP address or browser plug-in. This analysis is fundamental to the running of our online business and we therefore undertake such monitoring in the pursuit of our legitimate interests in improving our Site, and to provide a better service and source of information to visitors. To find out more about our service providers and to learn how to opt out, please visit: Google Analytics: https://policies.google.com/privacy?hl=en Where applicable, we provide you with the option to opt out of the use of cookie feature(s), which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. In connection with viewing the Site to enable you to take advantage of the most attractive features of the Services, we recommend that you leave cookies active as we believe they will likely improve your experience. To learn more about your opt-out options, please visit: https://www.networkadvertising.org/understanding-online-advertising https://www.allaboutcookies.org/ https://tools.google.com/dlpage/gaoptoutAll content you submit to us. If you send us objectionable content or otherwise behave in a disruptive manner when using our Site, we may process Personal Data included in your messages to respond to and stop such behavior. We only process Personal Data in this way for the legitimate interests of ensuring that use of our Site is lawful, does not disrupt our systems, does not harass our staff or other individuals, to enforce our legal rights, and to comply with our legal obligations. Where we reasonably believe you are or may be in breach of the law (for instance, because content you send amounts to harassment or is defamatory), we may use your Personal Data to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content. Where we process Personal Data in this way, we will hold that Personal Data on our systems for as long as is reasonably necessary to achieve these objectives, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

4. Do We Share Your Personal Data with Anyone Else? We keep your Personal Data confidential, but may share or disclose it (i) with your consent, (ii) to our personnel, business partners, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy, (iii) to provide you with access to the Site and Services, (iv) to comply with laws, (v) to protect your rights, or (vi) to fulfill business obligations. If we provide your Personal Data to third parties, we shall only do so provided that they do not make independent use of the information and provide the same confidential treatment as we do. We only permit them to process your Personal Data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your Personal Data. Activities which are carried out by or in collaboration with third party service providers including our website hosting company, payment processor(s), product review processor, and Ella (our fulfilment service provider). In addition, we may disclose your Personal Data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention). If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the Personal Data we hold may be included as part of that sale, in which case you will be notified via email, your account and/or a prominent notice on the Site of any changes in ownership or use of your information, as well as any choices you may have regarding that information. We may use third-party advertising companies, such as Google and Facebook, to help you see and find our products. You may see Ella banners or ads when you are on other websites or applications. These companies may use information about your visits to the Site and other websites that are contained in cookies and other tracking technologies that we place on your device in order to provide advertisements about goods and services of interest to you. The Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so. Except as provided above, we will not provide your information to third parties.5. Your rights in relation to your Personal Data which we process. EU & Swiss Residents If you are a resident of a country in the European Economic Area (“EEA”) or Switzerland (“European Resident”), you have additional rights regarding your Personal Data. You can withdraw your consent to our collection or processing of your Personal Data or your personal information at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to such withdrawal, nor will it affect processing of your Personal Data or your personal information conducted in reliance on lawful processing grounds other than consent. The Site generally provides you with a reasonable means to view and change your profile information and you can opt-out of marketing communications at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. If you have any questions or comments about the processing of your personal information, you may contact us at: info@ellapads.com. You have the following rights over the way we process Personal Data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us: for a copy of Personal Data we are processing about you and/or to have inaccuracies corrected; to restrict, stop processing, or to delete your Personal Data; for a machine-readable copy of your Personal Data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and to make a complaint to a data protection regulator. If you are a resident of the EEA, you can find your local regulator’s contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. To make a request in relation to any of the aforementioned rights, please send your requests to info@ellapads.com. California & Nevada Residents. Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights regarding Ella’s collection, use, and sharing of their personal information. This Privacy Policy applies to “Consumers” as defined by the CCPA. In the event of a conflict between any of our policies, statements, or notices, including but not limited to this Privacy Policy, this section will prevail as to California Consumers and their rights under the CCPA. For purposes of this section only, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you, as defined under the CCPA. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you. Consistent with the CCPA, job applicants, current and former employees and independent contractors (“Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered consumers for purposes of this notice or the rights described herein.Ella does not sell your Personal Information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. We may disclose your Personal Information for the following purposes, which are not a sale: (i) if you direct us to share your Personal Information, (ii) to comply with your requests under the CCPA, (iii) disclosures as part of a merger or asset sale, and (iv) as otherwise required or permitted by applicable law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your Personal Information.We collect various categories of Personal Information when you use the Site, including identifiers, commercial information, internet or other electronic network or device activity information, geolocation data, and professional information. A more detailed description of the information we collect and how we use it is provided above. Under the CCPA, you have the following rights: Right to Know. You have the right to access and request that we inform you of the Personal Information we collect, use, or disclose to third parties; Right to Obtain a Copy. You have the right to make or obtain a transportable copy of your Personal Information that we have collected in the period that is 12 months prior to the request date and are maintaining. Right to Request Deletion. You have the right to request that we delete your Personal Information that we have collected from you and are maintaining. Please be advised, however, that exceptions under the CCPA may allow us to retain and use certain Personal Information notwithstanding your deletion request; and Right to Non-Discrimination. We will not discriminate against you in a manner prohibited by the CCPA for exercising any of your CCPA rights. Please note that to protect your information and the integrity of our Site and Services, we will need to verify your identity before processing your request. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.Additionally, Nevada law (SB §220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. Ella does not sell your personal information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law.All requests for information or changes to your preferences must be directed to: info@ellapads.com. Such requests must include the reference “Request for California Privacy Information” or “Request for Nevada Privacy Information” in the subject line and in the body of the message, and must include the email address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted to us if not submitted pursuant to the terms set forth above.6. Children. We do not use the Site to knowingly solicit information from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at info@ellapads.com or write to us at Ella, 23 Branford Place, Suite 1, Newark, 07102, US. We will delete such information within a reasonable time.

7. Security. We will take commercially reasonable, appropriate technical and organizational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Site and Services taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Site visitors and customers. In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorized disclosure of or access to the Personal Data transmitted, stored or otherwise processed by us. Please be aware that, while we make the security of our Site and your Personal Data a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your Personal Data with us, you accept the aforesaid and provide your information at your own risk.

8. International Data Transfers. We are a US Company and our servers are located in North America and Europe and the information that we collect directly from you will be stored in these servers. By submitting Personal Data to us, or to a third-party via the Site or Services, you acknowledge that you will be voluntarily transferring Your Data to the United States, a jurisdiction which may not provide the same privacy framework as other regions. We take steps to ensure that the data we collect under this Privacy Policy is stored and processed in accordance with this Privacy Policy regardless of where the data is located. There are agreements in place to ensure that Personal Data is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses. We use the European Commission’s standard contractual clauses where appropriate when exporting data to a processor outside of the EU. If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know by emailing us at (add email here). To find out more about the standard contractual clauses, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

9. Retention Periods or Criteria. We will hold your Personal Data for as long as is necessary for the relevant purpose for which that Personal Data was obtained unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Notwithstanding the foregoing, we retain Personal Data while your Account is active and not closed, and if you do not delete your Account, your Personal Data may remain within your Account even if you have not recently purchased a Product, for the purposes of providing you access to the Site, and as otherwise stated herein. You can delete your Account at any time by following the instructions in the Account settings. If you would like us to stop using or holding your Personal Data and/or would like to request its deletion, please email us at info@ellapads.com.

10. Changes. This Policy may be updated from time to time. We will notify you of any changes by posting the new Policy here EllaPads.com/terms, and, where feasible, by letting you know by email or your account.

11. Contact Us. Questions, comments and requests in relation to this Policy are welcome and should be addressed to Ella, 23 Branford Place, Suite 1, Newark, 07102, US and via email to info@ellapads.com Last Updated: June 25,2022