Privacy Policy

This Stilessa Privacy Policy (the “Privacy Policy”) strives to protect user privacy and information when using any system of Stilessa LLC or being in a contractual relationship between Stilessa LLC as a service provider and any natural person as a service user.

BY USING THIS WEBSITE https://stilessa.com (the “Website”) OR ANY OTHER SYSTEM / ONLINE ECOSYSTEM USED BY STILESSA LLC TO PROVIDE YOU SERVICES OR PRODUCTS (collectively – the “System“), YOU AGREE TO THIS PRIVACY POLICY, WHICH MAY GET UPDATED WITHOUT PRIOR NOTIFICATION.

1. General provisions and definitions

1.1 Stilessa LLC is a legal entity, incorporated under the laws of the State of [STATE OF INCORPORATION], USA, legal entity file No. [LLC FILE NUMBER], address [REGISTERED BUSINESS ADDRESS], USA (the “Company” / “us” / “we”), doing business as “Stilessa”.

1.2 Any person using the Company’s website, services or online store is considered to be a client of the Company (the “Client” / “You”).

1.3 The Company and the Client are legally bound by the Terms of Service (the “Agreement”), which governs the contractual relationship between the Company as a service provider and the Client, any natural person, as a service user, or a user of the System prior to / without logging in / creating an account (Account).

1.3.1 The Company operates an online retail store offering apparel, accessories and related lifestyle products for sale to consumers (the “Services”). The Services can be reached and used via the System as indicated in the Agreement. In order to process Your orders, You may choose to share certain information such as Your name, shipping address, billing address, phone number and payment details. This information is processed solely to deliver the requested Services, including fulfilling and shipping Your orders.

1.3.2 The latest version of the Agreement shall be available at the Website’s Terms of Service page.

1.4 This Privacy Policy shall be applicable and interpreted in line with the Agreement. The definitions set out in the Agreement shall be applicable to this Privacy Policy.

1.5 You can contact the Company by filling out the contact form on the Website, as well as by sending us an email or inquiry to info@stilessa.com. For matters regarding this Privacy Policy, as well as any privacy matter, we recommend contacting the Company via email at info@stilessa.com.

1.6 The Company shall have the right to unilaterally modify and / or update this Privacy Policy at any time without notice. Continuous use of the Services / System by the Client shall be deemed acceptance of the Privacy Policy in its latest, most updated version. Any Client shall periodically check and assess this Privacy Policy. Any updated version of this Privacy Policy comes into force at the moment it is published on the System.

1.7 The latest version of this Privacy Policy shall be available at the Website’s Privacy Policy page.

1.8 By agreeing to the Agreement as per the rules set forth in the Agreement, You are automatically agreeing to this Privacy Policy. For the avoidance of doubt, You acknowledge that by using the System in any way prior to creating an Account or without logging in to the System (for example, when browsing the Website), You are also bound by this Privacy Policy and Your data / information may be collected by the Company automatically.

1.9 If You disagree to be bound by this Privacy Policy in any scope or way, You must not use, or must immediately cease Your use of, the Services, System or any part of it, as well as its features and functionalities.

1.10 The Company values the trust that You place in it when using the Services / System. For this reason, privacy and data security are extremely important to the Company. As soon as You use the Company’s System / Services, You entrust the Company with the processing of Your personal data. The Company wants to offer You the best possible shopping experience and continuously improve the System. This Privacy Policy explains what personal data the Company collects from / about You, how the Company processes it, and to whom it discloses it. It also explains the precautions the Company takes to protect Your personal data, what rights You have, and who You can contact regarding data protection issues.

1.11 In light of the above, the Company strives to protect Your privacy and undertakes to process Your personal data in accordance with the following rules and principles:

1.11.1 Processing shall be performed lawfully, fairly, and in a transparent manner.

1.11.2 Personal data must be adequate and limited to what is necessary in relation to the purpose for which it is processed.

1.11.3 Personal data shall be accurate and, where necessary, kept up to date.

1.12 This Privacy Policy is prepared in accordance with applicable United States federal and state privacy laws, including but not limited to the California Consumer Privacy Act (the “CCPA”).

1.13 With regard to terms used in this Privacy Policy, such as “Personal Information,” “Consumer,” “Business Purpose,” and “Service Provider,” we refer to the definitions set forth in the CCPA and other applicable US state privacy statutes. Any reference to “Processing” shall be understood as the collection, use, storage, or disclosure of information as defined under these applicable laws.

2. Applicability

2.1 This Privacy Policy applies to all persons who use the System / Services or otherwise interact with the Company (e.g., customers, business partners, interested parties, service providers, etc.), generally referred to hereinafter as “Client” or “You.”

2.2 The Company’s System and Services are not meant for anyone under the legal age. Only people of legal age are allowed to use the System, Services, place orders and register for an Account. The Company does not knowingly collect personal data from minors. If You are under 18 years of age, or under the legal age applicable to You, please do not use the System / Services and do not provide us with any personal data.

3. Obligations and Scope

3.1 For the purposes of the CCPA and other applicable US privacy laws, the Company is a “Business” (the entity that determines the purposes and means of processing Consumers’ Personal Information).

3.2 This Privacy Policy applies to the collection and processing of Personal Information by the Company from Clients (You) residing within the United States. You acknowledge that the Company may utilize infrastructure, global affiliates, or service providers located in various jurisdictions to perform the Services, including for order fulfilment and shipping.

3.3 If You have any questions regarding the processing of Your Personal Information, You can contact us at info@stilessa.com.

3.4 To protect Your privacy and security, the Company requires a verifiable client request for certain inquiries. We may require additional identification data from You to ensure that Personal Information is only disclosed to the authorized Client.

3.5 Obligations of the Company:

3.5.1 Data Hosting and Transfers. The Company manages Personal Information primarily within the United States. However, Your information may be stored or processed in any country where we or our service providers (including our e-commerce, payment, and marketing platform providers) maintain facilities. By using the System, You understand that Your information may be transferred to and maintained on computers located outside of Your state or country.

3.5.2 Data Protection. The Company shall implement and maintain reasonable security procedures and practices appropriate to the nature of the information, designed to protect Personal Information from unauthorized access, destruction, use, modification, or disclosure.

3.5.3 Data Breach Notification. In the event of a security breach involving unauthorized access to unencrypted Personal Information, the Company shall comply with applicable US state data breach notification laws. Notifications will be made as expeditiously as possible and without unreasonable delay, consistent with the legitimate needs of law enforcement.

3.5.4 Data Retention. The Company shall not retain Personal Information for longer than is reasonably necessary for each disclosed business purpose. Following this period, the Company shall securely delete or de-identify the information.

3.5.5 Sensitive Personal Information. In general, the Company does not process “Sensitive Personal Information” (such as social security numbers or precise geolocation). If You choose to provide such data, the Company will only process it to provide the Services. You have the right to limit the use of Your Sensitive Personal Information.

4. Personal Information Categories and Sources

4.1 Sources of Collection. The Company collects Personal Information from You in the course of providing the Services, when You browse the Website, place an order, create an Account, contact us for customer support, or subscribe to our newsletter. We also collect information automatically via cookies and tracking technologies when You interact with the System.

4.2 Categories of Personal Information Collected. In the preceding 12 months, the Company has collected and may continue to collect the following categories of Personal Information:

4.2.1 Identifiers and Contact Data. When creating a user Account, placing an order, or communicating with the Company, we process basic details such as Your name, email address, phone number, shipping address, and billing address.

4.2.2 Commercial and Order Data. In the context of placing an order, we process information relating to the products You purchase, browse, add to a cart or wishlist, or return, as well as Your order history and purchase preferences.

4.2.3 Financial Data. For the purpose of processing payments, orders, and refunds, we (or our third-party payment processors, such as Shopify Payments and other supported payment gateways) process payment details, including transaction IDs, payment methods, and truncated credit card information. The Company does not directly store full payment card numbers.

4.2.4 Internet or Other Electronic Network Activity (Log Data). During Your use of the System, we automatically collect data including, but not limited to: IP address, traffic data, transaction timestamps, computer or mobile device information, operating system, browser type, device type, and unique device identification numbers.

4.2.4.1 Usage Information: We track the frequency, time, and length of visits, pages viewed, products browsed, and page interaction data.

4.2.4.2 Cookies and Product Analytics: We collect data via cookies and services such as PostHog, which may include access dates/times, pages viewed, features used, and unique device identifiers. Where enabled, this may also include session replay / heatmap data showing how You interact with pages on the Website (e.g., clicks, scrolling and cursor movement), captured in a manner that masks sensitive input fields such as payment details. This data may be used in an aggregate or de-identified format to understand shopping behavior and improve the Website.

4.2.5 Advertising and Marketing Data. If You visit the System or our social media pages, we may process statistical and marketing data, including visitor counts, click-through rates, target group demographics, and consumer behavior / preferences derived from cookies and similar technologies (e.g., the Meta / Facebook Pixel and similar advertising tags).

4.2.6 Marketing and Email Data. If You subscribe to our newsletter or marketing communications (including through our email marketing platform, MailerLite), we process Your email address, name, purchase history, and engagement data (such as opens and clicks) to send You product updates, promotions, and other marketing communications.

5. Business Purposes for the Collection and Use of Personal Information

5.1 The Company collects and processes Your Personal Information for specific business and commercial purposes in accordance with applicable US state and federal laws. We do not require a specific “legal basis” as defined under foreign regulations, but rather provide this information to ensure transparency regarding how Your data is used to support our operations.

5.2 Operational and Contractual Purposes. The Company processes Personal Information to fulfill our contractual obligations to You under the Agreement, including: Order Fulfilment – processing, packing and shipping Your orders and communicating with You about order status; Account Management – establishing and managing Your Account and verifying Your identity; Transaction Management – processing payments, managing billing, and facilitating refunds, exchanges or credits through our third-party service providers; Customer Support – responding to inquiries, handling returns, and providing administrative notices.

5.3 Consent-Based Processing. In certain circumstances, we may ask for Your express consent to process Your Personal Information for specific purposes not otherwise covered by this Privacy Policy. Opt-In/Opt-Out: Where You have provided consent (such as for our newsletter or promotional emails), You may withdraw that consent at any time by clicking “unsubscribe” in any marketing email or by contacting us at info@stilessa.com. Multimedia Usage: Using Your photo, video, or testimonial content for promotional purposes, provided You have explicitly shared such content for these purposes (for example, tagging us on social media or submitting a customer review).

5.4 Legal Compliance and Fraud Prevention. We process Personal Information to comply with our legal obligations and protect the integrity of the System: Regulatory Compliance – maintaining records for tax, accounting, and corporate governance; Law Enforcement – providing information to authorities in response to valid legal processes, such as subpoenas or court orders; Anti-Fraud – monitoring for and preventing unauthorized or fraudulent transactions, chargebacks, and other malicious activities.

5.5 Legitimate Business Interests. The Company processes Personal Information to further our legitimate business interests, provided these interests are not overridden by Your privacy rights, including: Product Development – conducting market research, analyzing shopping behavior, and performing statistical analysis to improve our products and the Services; Network Security – implementing measures to protect the System from cyberattacks and ensuring the availability and resilience of our infrastructure; Marketing Optimization – running and measuring the performance of advertising campaigns across platforms such as Google and Meta; Legal Claims – asserting, exercising, or defending legal claims in the context of litigation or regulatory proceedings.

5.6 Publicly Available Information. The Company may process Personal Information that You have voluntarily made public (for example, information shared on public social media profiles, product reviews, or public forums), in accordance with applicable law.

6. Social Media Presence and Third-Party Communication

6.1 The Company maintains a presence on various social media platforms to communicate with active and potential Clients and to share news regarding our products. When You access these platforms, the terms of service and privacy policies of those specific operators apply. You acknowledge that these platforms may process Your data in jurisdictions with different legal frameworks than Your own.

6.2 Third-Party Tracking. As part of the technical processes of various social media platforms (e.g., Meta, Google, TikTok, Pinterest), these providers may identify if You are logged into Your social media account while visiting the System. This data is collected by the social media platforms and assigned to Your social media accounts, regardless of whether You interact with our specific content on those platforms. To prevent this association, You should log out of Your social media accounts before using the System.

6.3 Disclaimer of Liability. The activities, data collection, and processing practices of social media companies are not controlled by the Company. We do not accept any liability for any damage or loss You may suffer resulting from the use of Your data by these third-party operators.

6.4 Direct Communication. The Company only processes Personal Information from social media users when they communicate directly with us via such platforms (e.g., direct messages, comments, or customer inquiries). In these instances, the Company is responsible only for the processing of data that we directly receive and record. All other background data processing is the exclusive responsibility of the platform provider.

6.5 Opt-Out and Rights. For detailed information on how social media providers process Your data and Your options for objecting (opting out), please refer to the respective privacy policies of those providers. Requests for information or the exercise of privacy rights regarding data held by social media operators must be directed to the providers themselves.

6.6 The Company’s current social media accounts are listed on the Website. This list is non-exhaustive and the Company is entitled to change or add social media accounts at any time.

6.7 You should always make sure that a social media account is genuinely the Company’s before submitting or revealing any personal information while engaging in social media communication (for example, exchanging messages or leaving a comment).

6.8 You should be aware that SMS / messaging and email services are susceptible to spoofing and phishing attacks and should be careful when reviewing messages that claim to be from the Company. You should always use the communication tools on the System or contact us via email at info@stilessa.com if You are unsure about the authenticity of a communication or notice. The Company takes no responsibility for any loss due to spoofing, phishing, or other equivalent attacks.

7. Your Privacy Rights and Choices

7.1 Depending on Your state of residence, You may be entitled to the following rights regarding Your Personal Information:

7.1.1 Right to Know and Access. You have the right to request that the Company disclose certain information to You about our collection and use of Your Personal Information over the past 12 months. Once we receive and confirm Your verifiable client request, we will disclose to You the categories of Personal Information we collected about You, the categories of sources of that information, our business or commercial purpose for collecting or sharing it, the categories of third parties with whom we disclose it, and the specific pieces of Personal Information we collected about You.

7.1.2 Right to Delete. You have the right to request that the Company delete any of Your Personal Information that we collected from You and retained, subject to certain exceptions (such as if the data is necessary to complete a transaction, detect security incidents, or comply with a legal obligation).

7.1.3 Right to Correct. You have the right to request that the Company correct inaccurate Personal Information that we maintain about You, taking into account the nature of the Personal Information and the purposes of the processing.

7.1.4 Right to Opt-Out of Sale or Sharing. You have the right to direct the Company not to “sell” Your Personal Information for monetary value or “share” Your Personal Information for cross-context behavioral advertising or targeted advertising purposes.

7.1.4.1 While the Company does not sell Personal Information for monetary payment, our use of third-party advertising and analytics cookies (such as PostHog and the Meta Pixel) may constitute “sharing” or “processing for targeted advertising” under certain state laws. You may exercise Your opt-out rights through our cookie management tool or by sending a request to info@stilessa.com.

7.1.5 Right to Limit Use of Sensitive Personal Information. If the Company processes “Sensitive Personal Information” (as defined by state law), You have the right to request that we limit our use of such information to that which is necessary to perform the Services.

7.1.6 Right to Non-Discrimination. We will not discriminate against You for exercising any of Your privacy rights. Unless permitted by law, we will not deny You goods or services, charge You different prices, or provide a different level or quality of service.

7.1.7 Right to Withdraw Consent. Where processing is based on Your express consent (e.g., for marketing emails), You have the right to withdraw that consent at any time by clicking “unsubscribe” in any marketing email, managing Your preferences in Your Account, or emailing info@stilessa.com. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

7.2 Verification Process. To exercise the rights described above, please submit a verifiable client request to the Company via email at info@stilessa.com or through the contact form on the Website. Only You, or a person authorized to act on Your behalf, may make a verifiable client request related to Your Personal Information. We cannot respond to Your request if we cannot verify Your identity or authority to make the request.

7.3 Response Timing and Format. We endeavor to respond to a verifiable client request within 30 days of its receipt. If we require more time (up to 90 days), we will inform You of the reason and extension period in writing.

7.4 In the United States, privacy rights are enforced by state and federal authorities. If You believe Your rights have been violated, You may have the right to lodge a complaint with the Federal Trade Commission (FTC) or the Attorney General of Your state of residence.

7.4.1 Universal Opt-Out Mechanisms. Where required by applicable law, if our System detects that Your browser is transmitting a recognized opt-out preference signal, such as Global Privacy Control (GPC), we will treat this as a valid request to opt out of the “sharing” of Your personal information for targeted advertising for that browser.

7.5 If the Company declines to take action on Your request to exercise a privacy right, You may have the right to appeal our decision depending on Your jurisdiction of residence. To initiate an appeal, please contact us at info@stilessa.com within 45 days of receiving our notice of denial. We will respond to Your appeal in writing within the period required by applicable law, providing a detailed explanation of our decision and, where required, information on how to contact the relevant regulatory authority or Attorney General to lodge a further complaint.

7.6 Although the System is intended for use within the United States, if You are visiting from outside the United States, please note that Your Personal Information is being processed by the Company in accordance with this Policy. We provide all users, regardless of location, the ability to exercise the rights of access, correction, and deletion as described in this Section, to the extent required by applicable law.

8. Data Security and International Transfers

8.1 Commitment to Security. The security of Your Personal Information is of paramount importance to the Company. We maintain a comprehensive information security program consisting of administrative, technical, and physical safeguards designed to protect Personal Information from unauthorized access, destruction, use, modification, or disclosure.

8.2 Technical and Organizational Measures. To ensure a level of security appropriate to the risk, the Company has implemented the following measures: staff training; SSL/TLS encryption on the System through which we transfer personal data; use of a reputable, PCI-compliant e-commerce platform (Shopify) for order and payment processing; access controls restricting who can view customer data; regular review and assessment of our security practices; and incident-response procedures in the event of a security issue.

8.3 To facilitate our operations and provide the Services, the Company may transfer, store, and process Your Personal Information in jurisdictions other than Your state of residence, including through our hosting, payment, and marketing service providers. By using the System and providing Your Personal Information, You acknowledge and consent to this transfer and processing. The Company takes steps designed to ensure that Your Personal Information receives an adequate level of protection wherever it is processed.

8.4 When we transfer Personal Information to third-party partners, we implement appropriate safeguards designed to ensure that Your data remains protected in accordance with this Privacy Policy, including data processing agreements with our service providers. We conduct reasonable diligence on our service providers to verify that they maintain security practices appropriate to the nature of the information we entrust to them.

9. Disclosure and Recipients of Personal Information

9.1 General Principles. The Company will only disclose Your Personal Information to the extent described in this Privacy Policy or as specifically instructed by You at the time of collection. The Company does not sell Your Personal Information to third parties for monetary compensation.

9.2 Internal Disclosure. Within the Company, access to Your Personal Information is restricted to those individuals or contractors who require the information to fulfill our contractual and legal obligations, such as order processing, customer support, and fraud prevention.

9.3 Service Providers. We disclose Personal Information to third-party Service Providers that perform functions on our behalf, including but not limited to:

– E-commerce Platform: Shopify Inc., which hosts our online store, processes orders and manages our Account and cart systems.

– Payment Processing: PCI-compliant payment processors (including Shopify Payments and similar gateways) for handling transactions and refunds.

– Product Analytics: PostHog, used to analyze Website traffic, shopping behavior, feature usage and, where enabled, session replay / heatmap data.

– Advertising: The Meta / Facebook Pixel and similar advertising technologies, used to measure and optimize advertising campaigns.

– Email Marketing: MailerLite, used to send newsletters, order updates, and promotional communications.

– Shipping and Fulfilment: Carriers and fulfilment partners used to deliver Your orders.

– Professional Advisors: Legal, accounting, and insurance providers.

All such Service Providers are contractually or otherwise prohibited from retaining, using, or disclosing Your Personal Information for any purpose other than the specific business purpose for which it was disclosed to them.

9.4 Legal and Safety Disclosures. We may disclose Your Personal Information to third parties (i) if we are required to do so by law, regulation, or legal process (such as a subpoena or court order); (ii) to respond to requests from government agencies or law enforcement authorities; (iii) if we believe disclosure is necessary to prevent physical harm or financial loss; or (iv) in connection with an investigation of suspected or actual fraudulent or illegal activity.

9.5 Business Transfers. In the event that the Company is involved in a merger, acquisition, reorganization, or sale of assets, Your Personal Information may be transferred as part of that transaction. We will provide notice before Your Personal Information is transferred and becomes subject to a different privacy policy.

9.6 Requested Transfers. The Company may transmit Your Personal Information to another person or entity at Your specific request and with Your express consent, or as necessary to fulfill a contract You have entered into with us.

10. Retention Period

10.1 Unless otherwise indicated in a notice or consent form, the Company shall keep Your personal information only for as long as necessary to: provide You with the Services You have ordered and ensure proper use of the System / Account; comply with applicable laws, including mandatory recordkeeping periods (e.g., for tax and accounting purposes); and support a claim or defence in court or other legal proceedings.

10.2 Account and order data shall generally be retained for the duration of Your relationship with the Company and thereafter for a period necessary to comply with legal obligations, resolve disputes, and enforce our legal agreements, unless a shorter period is required by applicable law. Marketing data (such as Your email subscription) will be retained until You unsubscribe or request deletion.

11. Cookie Policy

11.1 The System, now and in the future, uses cookies and similar tracking technologies.

11.2 Insofar as those cookies are not strictly necessary for the provision of the System and Services, we will ask You to consent to our use of cookies when You first visit the System.

11.3 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server every time the browser requests a page from the server. Cookies may be either “persistent” (remaining valid until an expiration date or manual deletion) or “session” cookies (expiring when the browser is closed). Cookies may not contain any information that identifies a user personally, but personal data that we store about You may be linked to information stored in and obtained from cookies.

11.4 We use cookies and similar tracking technologies to enhance Your shopping experience, ensure the security of our System, and analyze our performance. These technologies fall into the following functional categories:

11.4.1 Necessary Cookies, which enable core System functionality, such as keeping items in Your cart, secure checkout, and account login. The System cannot function properly without these. We also use cookies as a security element to protect Your account and prevent fraudulent use of login credentials.

11.4.2 Preference Cookies, which remember information that changes the way the System behaves or looks, such as Your preferred currency, region, or display preferences.

11.4.3 Statistic / Analytics Cookies (such as PostHog), which help us understand how visitors interact with our online store by collecting and reporting information anonymously, including page views, feature usage and, where enabled, session replay or heatmap data, allowing us to measure and improve the shopping experience.

11.4.4 Marketing Cookies (such as the Meta / Facebook Pixel and similar advertising tags), used by us and our service providers to track visitors across websites, with the intent of displaying advertisements that are relevant and engaging to the individual user.

11.4.5 We use cookies to record and honor Your preferences regarding the use of non-essential cookies.

11.5 Managing cookies. Most browsers allow You to reject and delete cookies through their settings. Up-to-date guides for major browsers are provided below:

11.5.1 https://support.google.com/chrome/answer/95647 (Chrome)

11.5.2 https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox)

11.5.3 https://help.opera.com/en/latest/security-and-privacy (Opera)

11.5.4 https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari)

11.5.5 https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge)

11.6 You can manage Your preferences relating to the use of cookies on our System at any time through our cookie management tool, where available.

11.7 The Company may use a third-party service provider for handling cookie consent and preferences.

12. Our Details

12.1 This Privacy Policy is issued by Stilessa LLC, doing business as “Stilessa.”

12.2 You can contact us via the contact form on our Website, https://stilessa.com, or by emailing Your inquiry to info@stilessa.com.

Effective date: July 13, 2026