PRIVACY POLICY

Effective Date: June 24, 2026

Welcome to SOLLEN INC. (“Sollen,” “we,” “us,” or “our”). We operate the website located at www.sollenwatch.com (the “Website”) and provide related e-commerce services, features, and content (collectively, the “Services”).

This Privacy Policy and U.S. State Privacy Notice (“Notice”) explains how we collect, use, disclose, sell, share, and retain Personal Information about consumers, including residents of California, Virginia, Colorado, Connecticut, Utah, Texas, and other U.S. states with comprehensive privacy laws. It applies to all Personal Information collected through our Website, mobile applications, customer service interactions, and any other touchpoint linking to this Notice.

1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT, DISCLOSE, AND SHARE

Within the preceding 12 months, and currently, we collect various categories of Personal Information. The table below details these categories under the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA) frameworks, their sources, business purposes, and the categories of third parties to whom we disclose or share data for cross-context behavioral advertising.

CCPA / Statutory Category	Specific Examples of Data Collected	Sources of Collection	Business & Commercial Purposes	Categories of Third Parties Disclosed / Shared With
A. Identifiers	Legal name, alias, billing address, shipping address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, phone number, or other similar identifiers.	• Directly from you • Automatically via cookies • Third-party marketing networks	• Fulfilling and shipping orders • Account creation and authentication • Customer service • Targeted marketing and promotional communications	• Logistics and shipping carriers • Payment processors • Cloud hosting and database providers • Marketing and advertising networks
B. Personal Info Categories (Cal. Civ. Code § 1798.80(e))	Name, signature, physical characteristics, address, telephone number, credit card number, debit card number, or any other financial information.	• Directly from you when purchasing or registering	• Order checkout and fraud prevention • Processing refunds • Verifying identity for high-value transactions (e.g., luxury watches)	• Payment gateways (Stripe, PayPal, PingPong, OceanPayment) • Fraud mitigation and underwriting services
C. Commercial Information	Records of products purchased, obtained, or considered; shopping cart configurations; watch brand preferences; browsing history or tendencies on our site.	• Directly from you • Inferred from automated tracking technologies	• Inventory management • Optimizing product offerings • Personalizing user shopping experience • Deploying cart-abandonment emails	• Internal analytics platforms (Shopify Analytics, Google Analytics) • Retargeting advertising ad networks (Meta, Google Ads)
F. Internet / Electronic Network Activity	Browsing history, search history, clickstream data, information regarding your interaction with our Website, applications, advertisements, or marketing newsletters.	• Automatically via pixels, cookies, and web beacons embedded in the site and emails	• Debugging and repairing system errors • Information security monitoring • Measuring advertising campaign ROI and performance	• Data analytics providers • E-commerce platform infrastructure (Shopify) • Behavioral advertising platforms
G. Geolocation Data	Approximate location (e.g., country, state, city, or zip code) derived dynamically from your IP address or regional settings.	• Automatically via your browser or device connection metadata	• Tax compliance calculation based on delivery location • Adjusting displayed currency and localized language/shipping policies	• Geolocation lookup services • Automated sales tax compliance software
K. Inferences Drawn from Personal Info	Profiles reflecting your consumer preferences, characteristics, psychological trends, behavior, attitudes, and purchasing capacity regarding timepieces and accessories.	• Developed internally via multi-variable analysis of consumer interaction patterns	• Customer segmentation • Enhancing lookalike audience models for programmatic advertising	• Programmatic ad purchasing platforms • Data management platforms (DMPs)
L. Sensitive Personal Information	Account log-in credentials in combination with passwords allowing access to your specific user profile.	• Directly from you upon registration	• To secure your account and prevent unauthorized account takeovers	• Internal security infrastructure and encryption servers

2. DATA RETENTION PERIODS PER CATEGORY

We retain your Personal Information only for the duration necessary to fulfill the operational business and commercial purposes detailed in Section 1, or as strictly mandated by statutory requirements:

· Identifiers and Commercial Transactions Data: Retained for at least 7 years following a completed purchase transaction to satisfy corporate tax compliance, audit guidelines, and financial accounting laws.

· Internet and Electronic Network Activity: Automatically purged or anonymized within 14 to 26 months unless linked to an active user profile or required for critical network security diagnostics.

· Account Credentials (Sensitive Info): Retained continuously until the user actively initiates a verifiable account deletion request, or after 5 consecutive years of total account dormancy.

3. U.S. STATE PRIVACY DISCLOSURES: "SALE", "SHARING", OR TARGETED ADVERTISING

Under certain U.S. state privacy laws (including California, Virginia, Colorado, Connecticut, Utah, and Texas), the use of third-party tracking pixels and cookies for cross-context behavioral advertising may be legally defined as the "sale" or "sharing" of Personal Information, or processing data for "targeted advertising."

Within the preceding 12 months, we have utilized third-party analytics and digital advertising services (such as Google and Meta) that capture Identifiers (Category A) and Internet Activity (Category F).

· We do not sell your Personal Information to data brokers for direct monetary profit.

· We do share or process your data for targeted advertising purposes to deliver tailored advertisements to you on external digital platforms.

· We do not knowingly sell or share the Personal Information of consumers under the age of 16.

4. COMPREHENSIVE CONSUMER PRIVACY RIGHTS

If you are a resident of a U.S. state that grants comprehensive consumer privacy rights (such as California, Virginia, Colorado, Connecticut, Utah, Texas, etc.), you have specific statutory privileges regarding your data.

Summary of Rights:

1. Right to Know and Access: You have the right to request a disclosure of what Personal Information we have collected, used, disclosed, sold, or shared about you over the past 12 months, including the specific pieces of data, categories of sources, and business purposes.

2. Right to Request Deletion: You have the right to request that we delete Personal Information collected or maintained by us, subject to specific legal carve-outs (e.g., if the data is required to fulfill an active warranty, execute a return, complete a pending order transaction, or comply with legal holding requirements).

3. Right to Rectification / Correction: If you discover that any Personal Information we maintain about you is incorrect or incomplete, you have the right to request that we update and correct it.

4. Right to Opt-Out of Sale, Sharing, or Targeted Advertising: You have the right to direct us to stop selling or sharing your data for targeted or behavioral advertising.

5. Right to Limit Use of Sensitive Personal Information: You have the right to restrict our use of Sensitive Personal Information to purely necessary transactional operations. (Note: Sollen only uses sensitive data for secure log-ins, meaning this right is naturally restricted to its basic legal functionality).

6. Right to Non-Discrimination: We will not deny you services, charge you different prices, or provide a lower tier of service if you choose to exercise any of your statutory privacy rights.

5. SUBMITTING A PRIVACY REQUEST & VERIFICATION PROCESS

How to Submit a Request:

To exercise your Right to Know, Access, Delete, or Correct your data, please submit a verifiable request to our dedicated compliance team via email: sollensupport@sollenwatch.com.

Verification Mechanism:

To protect your sensitive financial and identity information, we must verify your identity before fulfilling any data access or deletion requests.

· Upon receipt of your email request, we will ask you to provide at least two to three pieces of identifying information that perfectly match data points stored within our secure system (e.g., verifying your billing address, order history ID, or matching the original account email address).

· If we cannot verify your identity to a reasonable degree of legal certainty, we reserve the right to deny the request to prevent malicious data harvesting.

Authorized Agents:

You may designate an authorized agent to submit a privacy request on your behalf. To do so, you must provide the agent with signed, written permission, and the agent must verify their own identity directly with us, or provide a valid Power of Attorney pursuant to probate laws.

Administrative Appeals (For VA, CO, CT, TX, and relevant jurisdictions):

If we deny your privacy request, you have the right to appeal our administrative decision. To initiate an appeal, reply directly to our denial email or contact us at sollensupport@sollenwatch.com within 60 days of the decision, stating clearly that you are invoking your statutory right to appeal. We will respond in writing within 45 days.

6. NOTICE OF FINANCIAL INCENTIVE / REWARDS SCHEMES

From time to time, we may offer special discount codes, coupons, or exclusive promotions (e.g., "10% off your first watch order") in exchange for your agreement to provide your email address or phone number for marketing subscription lists.

Under broad state privacy interpretations, these promotional initiatives may be classified as a Financial Incentive.

· Material Terms: By participating, you agree to receive recurring automated marketing emails or text messages from Sollen. You may opt out of these communications at any time by clicking the "Unsubscribe" link in our emails, or replying "STOP" to our texts.

· Valuation of Your Data: The financial value of your Personal Information (email/phone number) is directly tied to the unique operational margin of our promotional discount incentives, balanced against the procurement, data storage, and campaign distribution costs we incur to manage our automated consumer outreach systems.

· Voluntary Participation: Joining our subscriber list is completely voluntary. You can exit the program at any moment without penalty, and you will retain full access to our standard digital checkout features.

7. GLOBAL PRIVACY CONTROL (GPC) & BROWSER OPT-OUT SIGNALS

Our system architecture is designed to recognize and process automated user opt-out preferences, including the Global Privacy Control (GPC) signal broadcast by modern browsers or privacy extensions. If our platform detects a valid GPC signal from your device, we will automatically interpret that session as a directive to opt-out of the "sharing" or use of data for cross-context behavioral advertising for that specific browser environment.

8. CALIFORNIA "SHINE THE LIGHT" LAW

Pursuant to California Civil Code Section 1798.83, residents of California who provide personal data in obtaining products for personal, family, or household use are legally entitled to request and obtain from us, once per calendar year, a list detailing what customer information we shared, if any, with external business entities for their own direct marketing purposes. To submit this specific request, please email sollensupport@sollenwatch.com with "California Shine the Light Request" explicitly written in the subject line.

9. OWNER AND DATA CONTROLLER METADATA

For all general corporate questions, structural inquiries, or complaints concerning this Privacy Policy, please address your correspondence to our primary data controller:

· Corporate Entity: SOLLEN INC.

· Physical Infrastructure Location: 889 S Azusa Ave, City of Industry, CA 91748, United States

· Dedicated Legal Contact Gateway: sollen.team24h@hotmail.com