Privacy Policy

PRIVACY POLICY

Effective Date: July 9th, 2021

To review material modifications and

clarifications and their effective dates scroll to the bottom of the page.

This Privacy Policy describes our

handling practices and how we collect and use the Personal Data (defined below)

that you provide during your online and offline interactions with us.

Our Privacy Policy does not cover

the information practices of other companies and organizations who advertise

our services, and who may use cookies, web beacons (pixel tags), and other

methodologies to serve personalized ads.

If you are a resident of the

European Economic Area (EEA) consisting of the EU, plus Norway, Iceland, and

Liechtenstein, you have specific rights as described in this Privacy Policy. We

may act as the controller if we collect Personal Data from you directly. We may

also act as the processor if we process data transmitted from our subscribers

that have contracted for access and use of our online services.


HOW WE MODIFY THIS PRIVACY POLICY

We may modify this Privacy Policy at

any time, and without prior notice, by posting an amended Privacy Policy that

is always accessible by clicking on the “Privacy Policy” link on this site’s

web pages. Your continued use of this site indicates your acceptance of the

amended Privacy Policy.

Regarding Personal Data (defined

below), if any modifications are materially less restrictive regarding our use

or disclosure of the Personal Data previously disclosed by you, we will obtain

your consent before implementing such revisions with respect to such

information.

LEGAL BASIS FOR PROCESSING PERSONAL

DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are from the European

Economic Area (EEA), our legal basis for collecting and using Personal Data

described in this Privacy Policy depends on the Personal Data we collect and

the specific context in which we collect it.

We may process your Personal Data

because:

• We need to perform a contract with

you

• You have given us permission to do

so

• The processing is in our

legitimate interests and it’s not overridden by your rights

• For payment processing purposes

• To comply with the law

THE TYPES OF DATA WE COLLECT

Personal Data.

 

“Personal Data” means data about a

living individual who can be identified from those data (or from those data and

other information either in our possession or likely to come into our

possession).

Personal Data may include, but is

not limited to:

• First name and last name

• Email address

• Phone number

• Business name

• Website URL

• Address, State, Province,

ZIP/Postal code, City

• Any Personal Data you post on our

website

• Any Personal Data you post on a

social media platform

• Data about how you use our website

• Technical data such as your IP

address, your login data, details about your browser, time zone settings and

other technology on the devise you use to access our website

• Your marketing and communication

preferences

• Any information that you directly

provide to us whether through our contact form, over the phone, by email or

otherwise

• Geo-location data

• Cookies and Usage Data

Passively or Automatically Collected

Data (“Usage Data”).

We may also collect information

regarding how our service is accessed and used. This Usage Data may include

information such as your computer’s Internet Protocol address (e.g. IP

address), browser type, browser version, the pages of our service that you

visit, the time and date of your visit, the time spent on those pages, unique

device identifiers and other diagnostic data.

Geo-Location Data. If you are

accessing a page from a computer or a mobile device, you may be asked to share

your precise (GPS level) geo-location information with us so we can customize

your experience when we work with a marketing partner such as a third-party

service provider, advertiser, or advertising network and platform. If you agree

to the collection of location data, in most cases, you will be able to turn off

such data collection at any time by accessing the privacy settings of your

mobile device.

HOW AND WHEN WE COLLECT DATA

Personal Data. We collect Personal

Data on the public areas of our site through optin forms. We may collect

publicly available Personal Data posted publicly with social media profile

information.

Your Communications with Us. We

collect your Personal Data on the public areas of this site if you complete any

of our optin forms and/or participate in our follow-up.

Usage Data. We collect Usage Data as

you use the public areas of this site, including your interactions with emails

we send, and via social media platforms, and services of our marketing

partners. This data may be passively or automatically collected (that is,

gathered without your actively providing the information) using various

analytics and reporting technologies, such as cookies, web beacons, locally

stored objects, and mobile device identifiers and SDKs, and other similar

methodologies as well as similar technologies developed in the future. (See

below, SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS.)

HOW WE USE YOUR DATA

We may use your Personal Data

collected from the public areas of this site if you complete any of our optin

forms and/or participate in our follow-up.

We may use publicly available

Personal Data posted on social media profile information including photos for

purposes of assisting us, and our marketing partners with marketing and

advertising activities and with contact management.

RETENTION OF DATA

We will retain your Personal Data

only for as long as is necessary for the purposes set out in this Privacy

Policy. We will retain and use your Personal Data to the extent necessary to

comply with our legal obligations (for example, if we are required to retain

your data to comply with applicable laws), resolve disputes, and enforce our

legal agreements and policies.

We will also retain Usage Data for

internal analysis purposes. Usage Data is generally retained for a shorter

period of time, except when this data is used to strengthen the security or to

improve the functionality of our service, or we are legally obligated to retain

this data for longer time periods.

TRANSFER OF DATA

We are located in the United States.

Your submission of your Personal Data via this website will transfer your

Personal Data to us. We will not transfer your Personal Data outside the United

States unless the transfer is made to a country or territory recognized by the

EU as having an adequate level of data security, or is made with your consent,

or is made to satisfy our legitimate interest regarding our contractual

arrangements with our subscribers that have contracted for access and use of

our online services.

Your consent to this Privacy Policy

followed by your submission of your data to us signifies your agreement with

these transfers and storage of your data.

DISCLOSURE OF DATA

General Disclosure Policy. We may

share and disclose your Personal Data as described below.

Affiliated Entities. We may provide

your Personal Data and Usage Data to any affiliated entities we may have,

including our subsidiaries. Affiliated entities are entities that we legally

control (by voting rights) or that control us.

Service Providers. We may provide

access to your Personal Data and Usage Data to our trusted service providers

that assist us with the operation and maintenance of this site. For example, we

may contract with third parties to host our servers, provide security, and

optimization, analytics, reporting, and software maintenance and development

services. In addition, our service providers will be given access to your

information only as is reasonably necessary to provide the services for which

they are contracted.

Successors. If we sell or otherwise

transfer part or all of our business or assets to another organization, such as

in the course of an acquisition, merger, bankruptcy or liquidation, we may

transfer your Personal Data and Usage Data. In such an event, we will require

the buyer or transferee to agree to our commitments provided in this Privacy

Policy.

Legal Process, Enforcement and

Security Notice. We may disclose your Personal Data and Usage Data if we have a

good faith belief that access, use, preservation or disclosure of such

information is reasonably necessary (i) to satisfy any applicable law,

regulation, legal process or enforceable governmental request (such as for

example, to comply with a subpoena or court order), (ii) to detect, prevent,

and address fraud or other illegal activity, and (iii) to investigate, respond

to, or enforce violations of our rights or the security of this site.

Marketing Partners. We may share

your Usage Data with our marketing partners to serve and offer personalized

ads. We may share Personal Data with our marketing partners to correlate and

match our list with our marketing partners’ lists for purposes of creating an

“audience” for serving personalized ads.

With Your Consent. We may share your

Personal Data with other parties with your consent.

YOUR DATA PROTECTION RIGHTS UNDER

THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the

European Economic Area (EEA), you have certain data protection rights. We will

take reasonable steps to allow you to correct, amend, delete, or limit the use

of your Personal Data.

If you wish to be informed what

Personal Data we hold about you and if you want it to be removed from our

systems, please contact us.

In certain circumstances, you have

the following data protection rights:

The right to access, update or to

delete the information we have on you. Whenever made possible, you can access,

update or request deletion of your Personal Data directly within your account

settings section. If you are unable to perform these actions yourself, please

contact us to assist you.

The right of rectification. You have

the right to have your information rectified if that information is inaccurate

or incomplete.

The right to object. You have the

right to object to our processing of your Personal Data.

The right of restriction. You have

the right to request that we restrict the processing of your personal

information.

The right to data portability. You

have the right to be provided with a copy of the information we have on you in

a structured, machine-readable and commonly used format.

The right to withdraw consent. You

also have the right to withdraw your consent at any time where we have relied

on your consent to process your personal information.

Please note that we may ask you to

verify your identity before responding to such requests.

You have the right to complain to a

Data Protection Authority about our collection and use of your Personal Data.

For more information, please contact your local data protection authority in

the

European Economic Area (EEA).

SPECIFIC INFORMATION ABOUT COOKIES

AND WEB BEACONS

In order to provide better service

for our site, we and our marketing partners may use cookies and other data

collection methodologies discussed below to collect Usage Data to store your

preferences and information about what pages you visit and past activity at our

site and other websites. This information helps us and our marketing partners

display personalized ads, compile aggregated statistics regarding the

effectiveness of our promotional campaigns or other operations of our site. For

information about cookies from the FTC website visit –>

https://www.consumer.ftc.gov/articles/0042-online-tracking .

“Cookies” are tiny pieces of

information stored by your browser on your computer’s hard drive. Cookies are

also used to customize content based on your browser. Most browsers are

initially set to accept cookies. If you want to disable cookies, there is a

simple procedure in most browsers that allows you to turn off cookies. Please

remember, however, that cookies may be required to allow you to use certain

features of our site.

Flash Cookies – third party cookies

that use an Adobe Flash Media Player local shared object (LSO) – may be used

along with other third-party cookies for purposes of crediting any purchase you

may make on this site to one of our joint venture partners that may have

referred you to us. These cookies will be used for purposes of crediting sales

to the referring joint venture marketing partner. Flash cookies are not the

same as “browser cookies”. The Adobe Flash Media Player is software that

enables users to view content on their computers. Flash cookies are also

accompanied by a browser cookie. If you delete the browser cookie, the Flash

cookie may automatically create (or re-spawn) a replacement for the browser

cookie.

Web Beacons (sometimes called

single-pixel gifs or clear gifs) are used to assist in delivering cookies, and

they allow us to count users who have visited pages of our site. We may include

Web Beacons in promotional e-mail messages or our newsletters in order to

determine whether messages have been opened and acted upon.

Locally Stored Objects – we may

employ locally stored objects (“LSOs”) and other client-side storage tracking

technologies in certain situations where they help to provide a better user experience,

such as to remember settings, preferences and usage similar to browser cookies,

or in order to target or help our Partners target ads, analyze ad performance,

or perform user, website or market analytics. For LSOs utilized by Adobe Flash

you can access Flash management tools from Adobe’s website: –>

http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

. In addition, some, but not all browsers, provide the ability to remove LSOs,

sometimes within cookie and privacy settings.

PERSONALIZED ADS

We may participate with our

marketing partners for purposes of providing personalized ads based on your

interests. This activity is performed by collecting Usage Data and by using

cookies and other tracking and data collection methodologies discussed above to

transfer information to our marketing partners which manage advertising

activities.

Our marketing partners may also use

cookies and other tracking and data collection methodologies discussed above to

measure advertisement effectiveness and for other purposes that are disclosed

in their own privacy policies. We have no access or control over these cookies

and other tracking and data collection methodologies that may be used by our

marketing partners, and we have no responsibility or liability for the privacy

policies and practices of these sites.

AdWords (Google) – We may

participate in AdWords program which is a personalized ad service provided by

Google Inc. that connects the activity of this site with the Adwords advertising

network and the Doubleclick cookie. Information collected: cookie and Usage

Data. For the opt-out, visit –>

https://support.google.com/ads/answer/2662922?hl=en

Google Analytics for Display

Advertising (Google) – We may participate in any and all of the following

Google Analytics Advertising Features provided by Google: Google Analytics,

Google Display Network Impression Reporting, the DoubleClick Campaign Manager

integration, and Google Analytics Demographics and Interest Reporting. These

features use first party cookies (such as the Google Analytics cookie) for

connecting the tracking activity performed by Google Analytics and its cookies

with the Adwords advertising network and the DoubleClick cookie (a third-party

cookie). Information collected: cookie and Usage Data, including audience data

such as age, gender, and interests. For the opt-out, visit –>

https://support.google.com/ads/answer/2662922?hl=en You may opt-out of the

Google Analytics service with the Google’s Browser Add-on that’s available at

–> https://tools.google.com/dlpage/gaoptout

For information in general about

Google’s personalized ad campaigns, and specifically about information

regarding DoubleClick cookies and how to control and manage Google’s

advertising cookies for these campaigns, visit –>

http://www.google.com/policies/technologies/ads/

For another Google resource for

opting out of Google’s use of cookies, visit –>

http://www.google.com/settings/ads

For information regarding how Google

uses data when you use Google’s partners’ sites or apps, visit –>

http://www.google.com/policies/privacy/partners/

For an additional resource

recommended by Google for opting out of a third-party vendor’s use of cookies,

visit –> http://www.networkadvertising.org/managing/opt_out.asp

Custom Audience (Facebook). We may

participate in Facebook.com’s Custom Audience program which enables us to

display personalized ads to persons on our email lists when they visit

Facebook.com. We provide Personal Data such as your email address and phone

number to Facebook to enable Facebook to determine if you are a registered

account holder with Facebook. You may opt-out of participation in our Facebook

Custom Audience by sending an email, from the email address you are opting out

of, to the email address provided in our contact information below. For your

opt-out to be effective, you must: (i) place the following text in the subject

line of the email – “Opting Out of Facebook.com Website Custom Audience Ads”,

and (ii) in the body of the email, include your name and email address. We will

forward your name and email address to Facebook.com with a request to delete

you from all of our Facebook Custom Audience Ads.

Tailored Audiences/Conversion

Tracking Programs (Twitter). We may participate in Twitter.com’s Tailored Audiences/Conversion

Tracking Programs which enable us to display personalized ads. You may opt-out

of participation in these programs by visiting

https://support.twitter.com/articles/20170405 .

Other Personalized and Behavioral

Advertising services. We may participate in additional retargeting and

behavioral advertising services that will be similar to the services described

above.

Managing Personalized Ads. You can

control the placement of cookies and other data collection methodologies for

purposes of opting out.

Managing Cookies Via Your Browser.

You should note that although most browsers are initially set up to accept

cookies, you may be able to change your browser settings to cause your browser

to refuse first party or third-party cookies or to indicate when a third-party

cookie is being sent. However, disabling or limiting cookies may cause certain

features of this website to not function properly or optimally. Check your

browser’s “Help” files or other similar resources to learn more about handling

cookies on your browser. In addition, visit –>

http://www.allaboutcookies.org/manage-cookies/

Managing Flash Cookies. Flash

cookies, also called local shared objects (LSOs), function similarly to

standard cookies except that they are often larger and are downloaded to a

computer or mobile device by the Adobe Flash Player. In some cases, these Flash

cookies can be managed through browser settings. Adobe also provides a means of

controlling Flash cookies on its Flash Player: Setting Manager page.

Network Advertising Initiative

(NAI). A number of companies that use cookies to collect information about your

online activities are members of NAI, which offers a single location to opt out

of receiving personalized ads from member companies. To opt out of information

collection by NAI member companies, or to obtain information about the

technologies they use or their own privacy policies, please visit the NAI

consumer opt-out page: –> http://www.networkadvertising.org/choices/

Digital Advertising Alliance (DAA).

DAA member advertising associations have developed an industry self-regulatory

program to give consumers a better understanding of and greater control over

ads that are customized based on their online behavior across different

websites. To make choices about interest-based ads from participating third

parties, please visit DAA Consumer Opt-Out page –>

http://www.aboutads.info/consumers .

Opting Out with Ad Choices for

Mobile Devices. When using mobile applications you may receive personalized

in-application advertisements. Depending on your device, you may be able to

reset your mobile device’s advertising identifier at any time by accessing the

privacy settings on your mobile device. In addition, each operating system (iOS

for Apple phones, Android for Android devices and Windows for Microsoft

devices) provides its own instructions on how to prevent the delivery of

personalized in-application advertisements. You may review the support

materials and/or the privacy settings for the respective operating systems in

order to opt-out of these advertisements. For any other devices and/or

operating systems, please visit the privacy settings for the applicable device

or contact (or review the applicable privacy web page of) the applicable

platform operator.

ANALYTICS

We may participate with third party

analytics partners to monitor and analyze Web traffic and to keep track of user

behavior on this site.

Google Analytics (Google) – Google

Analytics is a web analysis service provided by Google Inc. (“Google”). Google

utilizes the data collected to track and examine the use of this site, to

prepare reports on its activities, and to share them with other Google

services. Information collected: cookie and Usage Data. Visit Privacy Policy at

–> https://www.google.com/intl/en/policies/?fg=1 You may opt-out of the

Google Analytics service with the Google’s Browser Add-on that’s available at

–> https://tools.google.com/dlpage/gaoptout.

DO NOT TRACK REQUESTS

Some Web browsers incorporate a “Do Not

Track” feature that signals to websites that you visit that you do not want to

have your online activity tracked. Each browser communicates “Do Not Track”

signals to websites differently, making it unworkable to honor each and every

request correctly. In order to alleviate any communication error between

browsers and website, we do not respond to “Do Not Track” signals at this time.

As the technology and communication between browser and website improves, we

will reevaluate the ability to honor “Do Not Track” signals and may make

changes to our policy.

DATA SECURITY

We will implement reasonable and

appropriate security procedures consistent with prevailing industry standards

to protect data from unauthorized access by physical and electronic intrusion.

Unfortunately, no data transmission over the Internet or method of data storage

can be guaranteed 100% secure. Therefore, while we strive to protect your

Personal Data by following generally accepted industry standards, we cannot

ensure or warrant the absolute security of any information you transmit to us

or archive at this site.

UPDATING PERSONAL DATA

Upon request, we will permit you to

request or make changes or updates to your Personal Data for legitimate

purposes. We request identification prior to approving such requests. We

reserve the right to decline any requests that are unreasonably repetitive or

systematic, require unreasonable time or effort of our technical or

administrative personnel, or undermine the privacy rights of others. We reserve

the right to permit you to access your Personal Data in any account you

establish with this site for purposes of making your own changes or updates,

and in such case, instructions for making such changes or updates will be

provided where necessary.

CHILDREN’S PRIVACY

We do not knowingly collect

personally identifiable information from anyone under the age of 18. If you are

a parent or guardian who has discovered that your child under the age of 18 has

submitted his or her Personal Data without your permission or consent, we will

remove the information from our active list, at your request. To request the

removal of your child’s information, please contact our site as provided below

under “Contact Us”, and be sure to include in your message the same login

information that your child submitted.

CONTACT US

Your California Privacy Rights.

Under California Law SB 27, California residents have the right to receive,

once a year, information about third parties with whom we have shared

information about you or your family for their marketing purposes during the

previous calendar year, and a description of the categories of personal

information shared. To make such a request, please send an email to the email

address provided in our contact information below and include the phrase

“California Privacy Request” in the subject line, the domain name of the

website you are inquiring about, along with your name, address and email

address. We will respond to you within thirty days of receiving such a request.

To address your individual rights or

if you have any questions regarding this Privacy Policy, please contact us at

the following:

website (at) wholesaleorprivatelabel.com