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Financial Incentive Notice

U.S. Financial Incentive Notice

Effective Date: 26 October 2026

Varley offers a 10% discount on eligible online orders when:

  • New customers sign up to receive Varley’s marketing newsletter via email;
  • Customers subscribe to receive marketing messages from Varley via SMS.

Because this offer involves the collection and use of personal information in exchange for a discount, it may constitute a financial incentive under California law.

Material Terms

Email:

To receive the promotional code, an eligible new customer must:

  • sign up to receive Varley’s marketing newsletter by providing their email address via the sign-up pop-up or footer appearing on the Varley website;
  • apply the promotional code at checkout; and
  • comply with the applicable promotional-code terms.

SMS:

To receive the promotional code, an eligible new subscriber must:

  • subscribe to receive marketing messages from Varley via SMS by providing their mobile number via the sign-up pop-up;
  • apply the promotional code at checkout; and
  • comply with the applicable promotional-code terms.

The 10% discount applies to the original retail price of eligible items on the customer’s online order. Each promotional code is single-use, non-transferable, and may not be combined with another promotion unless expressly stated. The discount does not apply to taxes, shipping charges, or handling fees. Additional exclusions or an expiration date may be communicated with the promotional code.

Personal Information Involved

In connection with the offer, Varley may collect and use:

  • your email address;
  • your mobile phone number;
  • your name, if requested;
  • your marketing and communication preferences;
  • information concerning newsletter engagement;
  • information concerning SMS messaging engagement;
  • information concerning issuance and redemption of the promotional code; and
  • associated purchase and transaction information if the code is redeemed.

Varley uses this information to administer the offer, send marketing communications, understand customer engagement, measure the effectiveness of its marketing, and develop its customer relationships and business.

How to Participate

You may opt in by submitting the requested information through Varley’s newsletter sign-up form and/or SMS sign-up form and agreeing to receive marketing communications. Participation is voluntary.

How to Withdraw

You may withdraw your consent to receive marketing communications at any time by selecting the unsubscribe link in a marketing email/SMS message or contacting Varley at support@varley.com. Withdrawing will stop future marketing emails and SMS messages, subject to the time reasonably necessary to process your request.

Withdrawing will not affect a promotional code already issued to you, which will remain subject to its original terms.

Withdrawal will not affect any discount properly applied to a completed purchase before withdrawal.

Value of Personal Information

Varley estimates in good faith that the value to Varley of the personal information and email newsletter relationship associated with the program is approximately $8.20 per participating customer.

Varley estimates in good faith that the value to Varley of the personal information and SMS subscription associated with the program is approximately $42.04 per participating customer.

Varley calculated these estimates using reasonable projections concerning:

  • the average incremental gross profit reasonably attributable to participating newsletter/SMS subscribers;
  • the expected duration of an active newsletter relationship/SMS subscription;
  • the percentage of newsletter/SMS subscribers who redeem the promotional code;
  • the average dollar amount of discounts redeemed; and
  • the costs of operating the program, maintaining subscriber information, sending marketing communications, and administering privacy and compliance obligations.

Based on this analysis, Varley has determined in good faith that the expected cost of providing the 10% discount bears a reasonable relationship to the estimated value of the personal information and newsletter/SMS messaging relationship associated with the program.

For more information about Varley’s privacy practices and your privacy rights, please review Varley’s Privacy Policy. Please also see our Terms and Conditions for further information.