Privacy policy

PRIVACY POLICY

Effective Date: November 19, 2025.

1. Introduction.

This Privacy Policy describes how Humming Pond LLC d/b/a Eittem collects, uses, discloses, and retains information about you as well as your choices regarding such information. For purposes of this Privacy Policy, unless otherwise stated, “information” or “personal information” means information relating to an identified or identifiable individual.

This Privacy Policy applies to information we collect where we control the purposes and means of processing, specifically information we collect through any of our websites, emails, advertisements, or other online services that link to this Privacy Policy (the “Service”). Please note that your use of the Service is subject to our Terms of Use.

This Privacy Policy does not apply to:

- the practices of third parties we do not control

- information collected in the context of your job application or employment with us

- information that has been anonymized or, to the extent permitted by law, deidentified

If you are a resident of the U.S., see our U.S. State-Specific Disclosures.
If you are located in the EEA, Switzerland, or the UK, see our EU Disclosures.

For our contact details, see the Contact Us section below.

2. How We Collect Information.

We collect information about you in a variety of contexts, as described below.

Information You Provide through the Service.

When you use the Service, you may be asked to provide information to us, such as when you create an account, sign up for our newsletters, or contact us. The categories of information we collect include:

- Contact Identifiers, including your name, email address, postal address, and phone number.

- Commercial information, including records of products or services you purchased, obtained, or considered.

- Account credentials, including your username, password, password hints, and other information for authentication or account access.

- Payment information, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments. This information is processed by our payment processors. For further information regarding payment processing, please see Shopify’s privacy policy at https://www.shopify.com/legal/privacy/app-users.

- Content, including content within any messages you send to us (such as feedback or questions).

Please do not provide any information that we do not request.

Information from Your Browser or Device.

When you use the Service, we and third parties we work with automatically collect information from your browser or device. The categories of information we automatically collect include:

- Device identifiers, including your device’s IP address and Ad ID.

- Device information, including your device’s operating software and browser (e.g., type, version, and configuration), internet service provider, and regional and language settings.

- Internet activity, including information about your browsing history and interactions, such as the features you use, pages you visit, content you view, time of day you browse, and referring and exiting pages.

- Non-precise location data, such as location derived from an IP address or data that indicates a city or postal code level.

This information is automatically collected through cookies and other tracking technologies incorporated into our Service, as described below:

- Cookies. Cookies are browser-based text files which are dropped on your browser when you visit a website, open or click on an email, or interact with an advertisement. There are various types of cookies, including session cookies (which are cookies that expire when you close your browser) and persistent cookies (which are cookies that do not expire until a set expiration date or you manually delete them). Cookies may be first party (which are cookies served directly by us) or third party (which are cookies served by third parties we work with).

- Pixels. Pixels (also known as web beacons) are code embedded in a service. There are various types of pixels, including image pixels (which are one-pixel transparent images) and JavaScript pixels (which contain JavaScript code). Pixels are often used in conjunction with cookies. When you access a service that contains a pixel, the pixel may permit us or a third party to collect information from your browser or device, or to drop or read cookies on your browser.

We use these tracking technologies for a variety of purposes, including to help make our Service work, personalize your browsing experience, prevent fraud and assist with security, perform measurement and analytics, and provide advertising (including targeted advertising).

Information from Other Sources.

We also collect information from other sources. The categories of other sources from which we collect information include:

- Business partners that offer co-branded services, sell or distribute our products, or engage in joint marketing or promotional activities.

- Third party vendors and related parties we work with in connection with receiving analytics, advertising, security, and fraud prevention services.

- Social media platforms with which you interact. For example, when you engage with our content on social media (such as through our brand page or direct messages), we may collect information such as your contact identifiers and any comments you provide. We may also receive additional information from the social media platform that you have authorized the platform to disclose to us. If you publicly reference our Service on social media (such as by tagging us or using a hashtag associated with us in a post), we may use your reference on or in connection with our Service.

- Public sources, such as information in the public domain.

Information We Infer.

We infer new information from other information we collect, including to generate information about your likely preferences or other characteristics.

3. How We Use Information.

We collect and use information in accordance with the practices described in this Privacy Policy. Our purposes for collecting and using information include:

- Providing services. We use information to provide services to you, including to operate the Service, establish and maintain your account, and provide support.

- Personalizing your experience. We use information to personalize your experience and show you content we believe you will find interesting.

- Communications. We use information to communicate with you about updates, security alerts, changes to policies, and other transactional messages. We also use information to personalize and deliver marketing communications to you, including by email and, where you opt in, by text.

- Analytics. We use information to understand trends, usage, and activities, for example through surveys you respond to and tracking technologies that we incorporate into the Service (such as Google Analytics).

- Advertising. We collect and use information to advertise our products and services. Various third parties such as ad agencies, ad networks, publishers, social media platforms, and technology providers may be involved in this process. For example, we place ads on third party publisher websites and social media platforms. These ads incorporate tracking technologies to help serve the ads, measure their performance, detect ad fraud, limit the frequency of ads shown, and provide insights. If you visit our Service after seeing an ad on a third party service, tracking technologies on our Service help us attribute conversions and determine how effectively we use our ad budgets.

Some of the advertising we engage in may be “targeted advertising,” which is the practice of showing you more relevant or personalized ads based on your activity collected over time and across non-affiliated services. Targeted advertising often involves us incorporating third party tracking technology into our Service or providing (often hashed) contact or device identifiers to a third party, which then matches common factor between our data and their data (or a partner’s data) to serve ads to you or individuals like you. For example, we incorporate the Meta pixel on our website to serve ads to audiences created by Meta based on the data we provide.

We also use audience modeling services, where we and a partner each provide (often hashed) data to a technology provider. The technology provider then matches common factors between our and the partner’s data to allow us to gain insights into audience overlap and campaign performance.

- Promotions. When you voluntarily enter a promotion, we use information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law. By entering a promotion, you agree to the official rules that govern that promotion, and that, except where prohibited by applicable law, we, the sponsor, and related entities may use your name, voice and/or likeness in advertising or marketing materials.

- Improvements. We use information to develop and improve our services.

- Security and enforcement. We use information to prevent, detect, investigate, and address fraud, breach of policies or terms, or threats or harm.

- At your direction or with your consent. We use information for additional purposes where you direct us to use it in a certain way or with notice to you and your consent.

- Non-personal information. Sometimes we anonymize or deidentify information so it is no longer considered personal information under applicable law. Where we deidentify information, we commit to maintain and use the deidentified information in deidentified form and not attempt to reidentify it. We may use non-personal information for any purpose to the extent permitted by applicable law.

To exercise choice around our use, see Your Privacy Choices below.

4. How We Disclose Information.

We disclose the information we collect in accordance with the practices described in this Privacy Policy. The categories of persons to whom we disclose information include:

- Service providers. Many of the third parties we work are service providers that collect and process information on our behalf. Service providers perform services for us such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers from processing information they collect on our behalf for purposes other than performing services for us, although we may permit them to use non-personal information for any purpose to the extent permitted by applicable law.

- Third party vendors and related parties. Some of the third parties we work with independently control the purposes and means of processing your information. For example, we disclose information to ad networks, technology providers, and other third parties that help provide targeted advertising. For these third parties, we encourage you to familiarize yourself with and consult their policies and terms of use.

- Affiliates. We disclose information to our affiliates and related entities, including where they act as our service providers subject to this Privacy Policy or use the information in accordance with their own privacy policies.

- Recipients in a merger or acquisition. We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

- Recipients for security and enforcement. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.

- Recipients at your direction or with your consent. We disclose information where you direct us to or with notice to you and your consent.

- Non-personal information. We may disclose non-personal information for any purpose to the extent permitted by applicable law.

To exercise choice around our disclosures, see Your Privacy Choices below.

5. Third Parties.

Our Service may link to, or be incorporated into, websites and online services controlled by third parties. In addition, we may integrate technologies into our Service, including those disclosed in the How We Collect Information section above, controlled by third parties. Except where third parties act as our service providers, they, and not us, control the purposes and means of processing any information they collect from you, and you should contact them directly to address any concerns you have about their processing. Third party data practices are subject to their own policies and disclosures, including what information they collect, your choices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

6. Your Privacy Choices.

Region-Specific Choice.

Some regions offer additional choice. If you are a resident of the U.S., see our U.S. State-Specific Disclosures. If you are located in the EEA, Switzerland, or the UK, see our EU Disclosures.

We provide a variety of ways for you to exercise choice, as described below.

Communications.

- Emails. To stop receiving marketing emails, follow the unsubscribe instructions near the bottom of such emails, or email us at inquiries@eittem.com as set out in the Contact Us section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of transactional emails.

Browser and Device Controls.

- Cookies and pixels. You may be able to manage cookies through your browser settings. When you manage cookies, pixels associated with such cookies may also be impacted. Please note that cookie management only applies to our website. If you use multiple browsers, you will need to instruct each browser separately. If you delete or reset your cookies, you will need to reconfigure your settings. Your ability to limit cookies is subject to your browser settings and limitations.

- Preference signals. Your browser or extension may allow you to automatically transmit Do Not Track and other preference signals. Except as required by law, we do not respond to preference signals.

- Third party opt-out tools. Some third parties we work with offer their own opt-out tools related to information collected through cookies and pixels. To opt out of your information being used by Google Analytics, please visit https://tools.google.com/dlpage/gaoptout. We are not responsible for the effectiveness of their tools.

- Industry opt-out tools for targeted advertising. Some third parties we work with are part of the National Advertising Initiative or follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising, which offer their own opt-outs tools for targeted advertising. For details, visit https://www.networkadvertising.org/choices/ and https://youradchoices.com/control. We are not responsible for the effectiveness of their tools.

Accounts.

If you have an account with us, you can delete your account by emailing us at inquiries@eittem.com with the words DELETE ACCOUNT in the subject field of the email. We will address your request in accordance with our data retention practices.

7. Children.

The Service is not directed toward children under 13 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us as set out in the Contact Us section below. We will delete the personal information in accordance with COPPA.

8. Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please note that transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

9. Retention.

We retain information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

10. International Transfer.

We are based in the U.S. If you are located outside the U.S., please be aware that your information may be transferred to and processed in the U.S. or another country where we operate. Where required by applicable law, we will provide appropriate safeguards for data transfers.

11. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide additional notice to you, such as through email or prominent notice on the Service.

12. Contact Us.

The controller under this Privacy Policy is:

Eittem (“Eittem,” “we,” “our,” or “us”)
601 W. 26th Street
New York, NY 10001
Privacy@eittem.com

If you have questions about our data practices or have trouble accessing this Privacy Policy, please contact us at the postal address or email address above. To exercise rights available to you, please use the designated methods listed in this Privacy Policy.

13. U.S. State-Specific Disclosures.

This section applies to residents of California and any Consensus State. A “Consensus State” is any U.S. state that has adopted a comprehensive privacy law. For purposes of this policy, Consensus States include Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia. This section does not apply to residents of other states except as expressly provided herein.

Notice at Collection

Our data practices are as follows:

- Collection. In the past 12 months, we have collected the categories of personal information set out in the How We Collect Information section above.

- Sources. The categories of sources from which we collect personal information are set out in the How We Collect Information section above

- Purpose. The specific purposes (including business and commercial purposes) for collecting and using personal information are set out in the How We Use Information section above.

- Disclosure. The categories of persons to whom personal information is disclosed, including service providers for business purposes, are set out in the How We Disclose Information section above. We disclose the categories of personal information listed in the How We Collect Information section above to service providers for business purposes.

- Sales, Shares, and Targeted Advertising. Some of our disclosures of personal information to third parties may be considered a sale or share for cross-context behavioral advertising purposes under applicable law. We also may process your personal information for purposes of targeted advertising as defined by applicable law. The categories of personal information we sell, share, or process for targeted advertising purposes include: identifiers, characteristics or demographics, commercial information, content, internet activity, non-precise geolocation data, and inferences drawn from any of the above. The categories of third parties to whom we sell, share, or disclose your personal information for targeted advertising purposes include, where applicable, vendors and other parties involved in cross-context behavioral advertising. We do not sell or share the personal information of consumers we know are under 16 years old.

- Retention. The criteria used to determine the period of time we retain your personal information is set out in the Retention section above.

Rights

This section sets out your rights. See Exercising Rights below for details on how to exercise your rights.

Verifiable Requests.

For California residents, you have the right to:

- Know what personal information we have collected about you, specifically have the right to know the categories of sources from which personal information was collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of personal information that we sold, shared, or disclosed for a business purpose, the categories of third parties to whom we disclosed personal information, and the specific pieces of personal information we have collected about you;

- Correct inaccurate personal information we maintain about you; and

- Delete personal information that we have collected from you.

For Consensus State Residents, you have the right to:

- Confirm whether or not we are processing your personal information, and in some regions, confirm the categories of personal information we have processed;

- Access your personal information;

- Correct inaccuracies in your personal information;

- Delete your personal information;

- Obtain a copy of your personal information that you previously provided to us in a portable and readily usable format

For Minnesota or Oregon residents, you also have the right to obtain a list of the specific third parties to which we have disclosed personal information.

For Delaware or Maryland residents, you also have the right to obtain a list of categories of third parties to which we have disclosed personal information.

For Connecticut residents, you also have the right to obtain a list of the specific third parties to which we have sold personal information.

- Opt-Out of Sales, Shares, and Targeted Advertising. You have the right to opt-out of us selling or sharing for cross-contextual advertising purposes your personal information to third parties, or processing your personal information for targeted advertising purposes.

- Revocation of Consent. You have the right to revoke consent previously given to us that we rely on to process your personal information. If you withdraw consent, you may not be able to receive certain services dependent on that consent.

- Nondiscrimination. You have the right not to be discriminated against for exercising any of your rights.

- Appeals. You have the right to appeal our decision in response to your requests.

- Authorized Agents. You may exercise your rights through an authorized agent.

Exercising Rights

This section sets out how to exercise your rights.

- Verifiable Requests. Verifiable requests require us to verify your identity before fulfilling them. To exercise any of these rights, submit a request through our form here (specifying the rights you wish to exercise) or call our toll-free number at 1-877-220-2101. If you have an account with us, we may require you to submit the request through your account. We will confirm receipt of and respond to your request consistent with applicable law. To verify your identity, we may require you to confirm receipt of an email sent to an email address that matches our records, provide us with details relating to your history with us, or provide additional information. If we cannot verify your identity, we may deny your request in accordance with applicable law.

- Sales, Shares, and Targeted Advertising. We do not typically associate information collected through tracking technologies on our website with other information in our systems. As a result, you may need to submit one opt-out for information collected through website tracking technologies, and a separate opt-out for other information in our systems (like your email address).

For website tracking technologies: Enable a recognized opt-out preference signal in your browser (such as Global Privacy Control) or adjust your cookie preferences here. This opt-out will apply only to the browser in which it is set, and, if you delete or reset cookies or switch browsers, you will need to opt-out again.

For information in our systems: Submit a request through our form here.

If we can readily associate the information collected through website tracking technologies with other information in our systems, such as you are logged into your account when you submit the request or we maintain a pseudonymous profile associated with the browser or device from which you submit the request, we will apply the opt-out more broadly across our systems where feasible.

- Consent. To revoke consent, write us at the email or postal address set out in the Contact Us section above (specifying the consent you wish to withdraw). If you withdraw consent, you may not be able to receive certain services related to that consent.

- Authorized Agents. Authorized agents must submit requests through the specific methods designated herein. Except where prohibited by law, we will require written and signed proof of the agent’s permission.

- Appeals. To appeal, write us at the email or postal address set out in Contact Us and specify what you wish to appeal. We will review and respond to your appeal in accordance with applicable law. If we deny your appeal, you may submit a complaint to your Attorney General as follows: Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia.

- Limitations. Your rights are subject to exceptions and our data retention practices. To the extent permitted by law, rights requests must be exercised through the applicable designated method specified herein

Additional California Disclosures

- Shine the Light. If you are a customer, you may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To make a request, write us at the email or postal address set out in the Contact Us section above and specify that you are making a “California Shine the Light Request.”

- Do Not Track. We do not respond to Do Not Track signals.

Disclosures for Nevada

For Nevada residents, you have the right to opt-out of sales of your personal information to third parties. To exercise your right, following the opt-out process in Exercising Rights above. Your rights are subject to exceptions and our data retention practices.

14. EEA, Switzerland, and the UK.

Data Practices

For individuals located in the European Economic Area, Switzerland, or the United Kingdom, our practices regarding the collection, use, disclosure, and retention of your personal data are set out in the main Privacy Policy above.

Lawful Basis for Processing

Data protection laws in your region require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners, or clients; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate safeguards, such as standard contractual clauses.

Requests

You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, submit a request through our form here or write us at the email or postal address set out in the Contact Us section above (specifying the rights you wish to exercise).

Complaints

You have the right to lodge a complaint with the data protection regulator in your jurisdiction.