Effective date: July 1, 2023

This Privacy Policy tells you how we collect, use and share information we collect on the website linked to this Privacy Policy and any of our apps, social media properties, other websites, marketplace pages, or blogs (individually, a “Site” and collectively referred to herein as the “Site” or the “Sites”). This Site is operated by Branded AcquiCo No 5, LLC (also referred to herein as “we,” “us,” or “our”) and is effective as of the date posted above. By using any of the Sites and/or submitting information, you agree that we may use and disclose your information according to the terms of this Privacy Policy.

Information collected
How we use your information
Cookies and tracking
Our Online Store
Sharing your personal information
Data Security
Your choices about your information and access to your information
Children’s information
Data Processing and Cross-Border Data Transfers
Notices to California residents
Notices to Nevada residents
Notices to European Union and United Kingdom residents
Data retention
Links to other websites, applications and services
Changes to our Privacy Policy
How to contact us

1. Information collected

We collect information when you visit our Sites or otherwise interact with us. This includes information you provide, information we receive from other sources and information that we automatically collect (as discussed below).

“Personal Information” is information that, directly or indirectly, identifies you or another individual and which may include, but is not limited to: name; title, company name; expertise; postal address; telephone number; email address; browser and device information (including Internet Protocol (IP) address); and information collected through cookies and other similar technologies. If you submit any Personal Information relating to another person or people to us or to our service providers in connection with the Sites, you represent that you have the authority to do so, have provided a copy of this Privacy Policy to the relevant individual, and that they permit us to use the information in accordance with this Privacy Policy.

Other information we collect and use includes information or data that does not and cannot be used to reveal your identity or that of another individual, such as information which has been fully and permanently anonymized and aggregated. We use this information to facilitate our operation of the Sites and for other purposes described below.

Information you provide

We collect information that you submit when visiting the Site including registration information (your name, email or postal address, telephone number and user name and password), contact information if you sign up for our newsletter or contact us with an inquiry (email address, telephone number), or customer information if you make a purchase (name, billing and shipping address, payment card information, email and telephone number). If our Site allows you to apply for employment with us we or our third party service provider will collect your application information which may include your resume, employment and education history, skills, personal references and other information you choose to submit.

You are not obliged to provide us with any Personal Information. If you fail to provide us with the Personal Information that we request or need, however, we may be unable to enter into an agreement with you – for the sale of our products or otherwise – or to otherwise respond to your requests.

Information we collect from other sources

We may also collect information about you from other sources, including our affiliates and third parties from whom we have purchased Personal Information, and combine this information with Personal Information provided by you. This helps us to update, expand and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. We may also collect Personal Information from business contact information, including mailing address, job title, email address, phone number, ‘intent data’ which is web user behavior data, IP addresses, social handles, LinkedIn URLs and custom profiles from third-party data providers for the purposes of targeted advertising, delivering relevant email content, event promotion and profiling.

We may also collect information about you from others including job applicant references, Site visitors who provide information about you when sending you a gift or referring you to our services, or social media connections, such as personal information about you if other users of a third-party website, app or interactive service give us access to their profiles and you are one of their "connections" or information about you is otherwise accessible through your "connections" web page, profile page, or similar page on a social networking or other third-party website, app or interactive service.

We may use a third-party service provider to manage and deliver our online orders and this service provider may collect information directly from you when you make a purchase and provide that information to us to fulfill your order. We may also use a third-party service provider to manage our staffing process by collecting and processing job applications submitted online. This service provider may collect information directly from you when you submit a job application and provide that information to us as part of our staffing management.

Automatically collected information

Device and usage data we process. We use common information-gathering tools, such as log files, cookies, web beacons and similar technologies to automatically collect information, which may contain Personal Information, from your computer or mobile device as you navigate our Site(s) or interact with emails we have sent you.

Log Files. As is true of most websites, we gather certain information automatically via log files. This collected information may include your IP address (or proxy server), device and application identification numbers, your general location, your browser type, your internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our Sites and to guarantee their security and continued proper functioning. We also collect IP addresses from users when they log into any "account" sections of our Sites as part of our security features.

Site use information. Our web servers may collect information including the IP address of visitors to our Site, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.

2. How we use your information

We use the collected information for our general commercial purposes such as to improve our Site, to grow our business, and to offer our products or services (including those of our affiliates, the Branded Group SA family of companies (the “Branded Group”), or third-parties) which we think may be of interest to you. We use your contact information to respond to your inquiries or to provide information on products or services to you.

Where your consent is not mandatory, we may process Personal Information on the following lawful bases:

For the performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract.
As necessary in certain legitimate interests (including our business interests), provided such interests are not overridden by your interests or fundamental rights.
As necessary for our compliance with legal obligations to which we are subject.

We will process Personal Information for the following purposes as is necessary for the performance of a contract or transaction between you and us, to answer questions, or take steps at your request prior to entering into a contract:

To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
To assist you in completing a transaction or order;
To prepare and process invoices;
To respond to queries or requests and to provide the services and associated support;
To provide customer relationship management;
To create and manage our accounts;
To notify you about changes to our services;
To allow you to subscribe to news, alerts or other publications; and
To allow you to sign-up to attend webinars or events.

We will process Personal Information for the following purposes as necessary for certain legitimate interests, including:

To offer our services or products or those of the Branded Group to you in a personalized way;
To send you personalized marketing communications where your consent is not required;
To allow you to participate in questionnaires, surveys, contests and surveys and benefit from personalized promotional offers;
To monitor quality control and ensure compliance with any and all applicable laws, regulations, codes and ordinances, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law;
To resolve any disputes;
As part of our efforts to keep our Sites, services and premises safe and secure;
To ensure the security of your account and our business and preventing or detecting malicious activity or abuses of our Sites and services, for example, by requesting verification information in order to reset your account password (if applicable);
To administer our Site and services, and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
To create products or services that may meet your needs; and
To develop and improve our products and services and those of the Branded Group.

We will process Personal Information for the following purposes as necessary for our compliance with legal obligations to which we are subject, including:

Preventing or detecting fraud;
Complying with applicable anti-money laundering (AML) laws; and
Complying with any applicable laws, regulations, codes and ordinances, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.

We may also process Personal Information where you have given your informed consent to such processing, for example where you have signed up to one of our mailing lists. Where you have provided your consent for our processing of Personal Information, such consent may be withdrawn at any time.

3. Cookies and Tracking Policy

This section provides our cookie policy and describes how we use cookies and similar technologies. With your consent, we use cookies and similar technologies to collect aggregate (non-personal) information about Site usage by all of our visitors and to help us remember you and your preferences when you revisit the Site. These cookies may stay on your browser into the future until they expire or you delete them. We also use technologies to remember your purchase selections in your shopping cart. As these technologies are strictly necessary for the Site to function, we do not need your consent to use them. These cookies are usually erased when you close your browser window. An explanation of cookies and similar technologies is set out below. Further general information about cookies and how they work is available at www.allaboutcookies.org.

Cookies. A cookie is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We use a variety of cookies, such as session, persistent and analytics cookies, among others, to identify and authenticate visitors and to store information in your electronic shopping baskets so it can be retrieved later.

With your consent, we allow selected third parties to place cookies on your device through the Site to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you. These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our website. We may also permit third party service providers to place cookies through our Site to perform analytic or marketing functions where you are notified of them and you have consented to their usage. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties. Your consent is collected by way of a “cookie banner” which will appear when you first visit the Site.

In addition to rejecting cookies using our cookies page, you can also disable or delete cookies by changing the preferences on your device browser (usually located in the “Help” or “Tools” menu). Disabling all cookies may, however, prevent you from using some of the essential features of our Site.

Web Beacons and Pixel Tags. We and our third-party service providers may use web beacons or pixel tags to control the automated collection of non-Personal Information. These small electronic tags on specific web pages on our Site help us monitor the activity on our Site in order to improve the performance of certain features and your shopping experience.

JavaScript. In order to collect the kinds of information described in this Privacy Policy and to see how you interact with our Site, we, or third parties, may use JavaScript or other languages to send instructions to your devices.

Do Not Track. Some browsers may provide a “Do Not Track” option which signals to websites and web services that you do not wish to have your online activities tracked over time or across different websites. A “Do Not Track” option may also allow you to opt out of behavioral advertising. At this time, because there is no consistent industry understanding of how to respond to “Do Not Track” signals, the Sites neither respond to nor support “Do Not Track” requests and will continue to collect information about your online activity as mentioned in this Privacy Policy notwithstanding our receipt of such signal or request.

4. Our Online Stores

Our online stores may utilize a third-party e-commerce and payment partner or e-commerce partner for subscription purchases, such as Shopify or ReCharge, which allows us to sell our products and services to you. Your Personal Information is stored through these databases and applications. They store your Personal Information on a secure server behind a firewall. If you choose a direct payment through our store to complete your purchase, then our partners store your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as necessary to complete your purchase transaction. Once complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS, as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. For more insight, you may also want to read our partners' Terms of Service and Privacy Statements here:

Shopify Terms of Service: https://www.shopify.com/legal/terms

Shopify Privacy Policy: https://shopify.com/legal/privacy

ReCharge Terms of Service: https://rechargepayments.com/terms-of-service

ReCharge Privacy Policy: https://rechargepayments.com/privacy-policy

Klaviyo Terms of Service: https://www.klaviyo.com/terms-of-service

Klaviyo Privacy Policy: https://www.klaviyo.com/privacy/policy

5. Sharing your information

We may reveal information about you to unaffiliated third parties:

if you request or authorize it;
if it is necessary to provide the information to complete a transaction for you;
if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection etc.);
if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets);
if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.);
if the information is provided to our professional advisors (such as lawyers or accountants); or
as otherwise described in this Privacy Policy.

We also share Personal Information with our affiliates, including the Branded Group, and we use it for group marketing purposes. We do not share mobile information outside of our affiliates and their authorized service providers.

We may, with your consent, also share your information with unaffiliated third parties for their marketing purposes. Where you have given your consent, you may withdraw this at any time. Withdrawing your consent will not however affect the legality of any processing (including sharing) previously undertaken on the basis of your consent.

6. Data Security

We have implemented appropriate organizational, technical, and administrative measures to protect Personal Information within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Information from loss, misuse, interference and unauthorized access, modification and disclosure you should keep in mind that the Site is run on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control.

You also play a role in protecting your information. You must maintain the security of your online transactions by not sharing your passwords and account information with any unauthorized parties. If we receive instructions using your log-in information we will consider that you have authorized the instructions. Please also be aware that despite our best intentions and the guidelines outlined in this Privacy Policy, no data transmission over the Internet or encryption method can be guaranteed to be 100% secure. We cannot guarantee the security of any information you transmit to us or our Site, and therefore you use our Site at your own risk. Please also take care when sending us Personal Information by email as email communications are not secure.

In the unlikely event that we believe the security of your Personal Information in our control may have been compromised, and this is likely to result in a high risk to your rights and freedoms we will try to notify you. To the extent you have provided us with your email address, we may notify you by email and you agree to our use of email as a means of such notification. If you prefer for us to use another method to notify you in this situation, please contact us using the information under “Contacting Us” below, with the alternative contact information you wish to be used.

7. Accessing your information and your choices

You can update, amend or delete your information at any time by logging into your online account.

You can choose not to receive emails from us by “unsubscribing” using the instructions in any email you receive from us. This will not stop us from sending emails about your account or your transactions with us.

You can edit your cookie preferences by visiting our cookie page. You can also choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies performance of the Site may be impaired and certain features may not function at all.

8. Children’s Privacy

This Site is not designed nor intended to be attractive to use by children under the age of 13. We do not knowingly collect information from children under the age of 13. If you are under 13 please do not submit any information to us. You must be at least 18 years of age to make purchases on the Site.

9. Data Processing and Cross-Border Data Transfers

Our Sites are maintained on virtual servers located in the United States, and personal information submitted is stored on our virtual servers in the United States. If you are visiting our Site from outside the United States, please be advised that your information is transferred to our U.S. servers. Disclosing your Personal Information to us pursuant to this Privacy Policy is at your own risk. We strive to comply with laws of jurisdictions in which we maintain operations but we make no representations that the practices described in this Privacy Policy are compliant with laws outside those jurisdictions that apply to the collection, security, use and disclosure of personal information.

Under certain circumstances we may have to transfer Personal Information subject to the GDPR or UK GDPR (as defined below) to countries outside of the EEA or UK and to entities located in jurisdictions which are not subject to an adequacy decision of the European Commission or UK Secretary of State. We will always ensure that we have a legal basis for such data transfer, and ensure a relevant safeguard method is in place (e.g. standard contractual clauses, including necessary assessments and supplementary measures) or a derogation applies, so that your Personal Information is treated in a manner that is consistent with, and respects the UK, European and other applicable laws and regulations on data protection. If you require further information about international data transfers, please send an email to privacy@joinbranded.com.

10. Notices to California Residents

A. Your California Privacy Rights

California residents with an established business relationship with us are permitted by California law once a year to request information about the manner in which we shared certain categories of information with others for their marketing purposes during the prior calendar year. Please email us at California@joinbranded.com to request this disclosure.

B. California Consumer Privacy Act Notice

The California Consumer Privacy Act as amended by the California Privacy Rights Act (“CPRA”) provides certain verified California residents with the right to: receive disclosure of our information collection and disclosure practices; the specific information collected about them; request that we correct information we hold; make requests that we do not sell information or do not share personal information for cross-context or behavioral marketing purposes; request that we limit processing of sensitive personal information to the purposes for which it was originally provided; or that we delete information subject to certain exceptions. For details on how to exercise these rights, please see below. We will not discriminate against you as a result of your exercise of any of these rights. For purposes of CPRA, “personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

Our California employees (current, former or applicants) can learn about our information collection and disclosure practices and how to exercise their CPRA rights by contacting a Human Resources team member.

1. Information Collected, Sources, and Business Purpose for Collection

The following table lists the categories of personal information defined in the CPRA, whether we have collected information in the category during the past 12 months, the sources of the information, and the business purposes for which we collect and use the information. The categories of information include information we collect from our Site ,visitors, registered users, employees, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals. For instance, we may collect different information from applicants for employment or from vendors or from customers.

Category of Information	Collected?	Source	*Business purposes for use**
A. Identifiers (name, alias, postal address, email address, phone number, account name, Social Security number, driver's license number, passport number, unique personal identifier, IP address)	Yes	Individuals submitting information to us; information we automatically collect from site visitors; information we may receive from third-party marketing and data partners.	Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair; ad customization; performing services for you; internal research and development; quality control.
B. Protected Information (name with: Social security number, driver’s license or state ID number, financial account, medical, health, and health insurance information, username and password)	Yes	Individuals submitting information; employment applications; employees.	Auditing relating to transactions; security detection, protection and enforcement; performing services for you; quality control.
C. Protected anti-discrimination classification information (Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).)	Yes	Individuals submitting information.	Performing services for you; internal research and development; compliance with law.
D. Commercial information (transaction history, products/services purchased, obtained or considered, product preference)	Yes	Individuals submitting information; information we automatically collect from site visitors; information we may receive from third-party marketing or data partners.	Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair; ad customization; performing services to you; internal research and development; quality control.
E. Electronic network activity (browsing or search history, website interactions, advertisement interactions)	Yes	Information automatically collected from site visitors.	Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair; ad customization; performing services for you; internal research and development; quality control.
F. Audio, video or similar information (customer service calls, security monitoring)	Yes	Individuals submitting information; information we collect for security purposes.	Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair; performing services for you; quality control.
G. Biometrics	No	Not collected	Not collected
H. Geolocation	Yes	Information we automatically collect from site visitors.	Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair; ad customization; performing services for you; internal research and development; quality control.
I. Professional, educational or employment related information	Yes	Information submitted by individuals; information received from third parties in connection with vendor or employment status or applications; information we observe in connection with vendor or employment oversight.	Auditing relating to transactions; security detection, protection and enforcement; performing services for you; employee and vendor management; internal research and development; quality control; compliance with law.
J. Non-public educational information)	No	Not collected	Not collected
K. Sensitive Personal Information (may include, social security, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, health, sex life or sexual orientation.)	Yes	Information submitted by individuals; information received from third parties in connection with vendor or employment status or applications; information we observe in connection with vendor or employment oversight.	Identity verification; employment and benefits administration; vendor oversight; security detection, protection and enforcement; compliance with law.
L. Inference from the above (preferences, characteristics, behavior, attitudes, abilities, etc.)	Yes	Internal analytics	Internal research and development; quality control.

*More specifically, the business purposes include:

i. Performing services for you:

To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
To assist you in completing a transaction or order;
To allow tracking of shipments;
To prepare and process invoices;
To respond to queries or requests and to provide services and support;
To provide aftersales customer relationship management;
To create and manage our customer accounts;
To notify you about changes to our services and products;
To administer any promotion, contest, survey, or competition;
To provide you information regarding our products and services; and
To offer our products and services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly.

ii. Advertising customization:

For marketing and promotions we believe you may find of interest and to provide you, or allow selected third parties to provide you, with information about products and services that may interest you.

iii. Auditing relating to transactions, internal research and development:

To provide for internal business administration and operations, including troubleshooting, Site customization, enhancement or development, testing, research, administration and operation of our Sites and data analytics;
To create products or services that may meet your needs; and
To measure performance of marketing initiatives, ads, and websites “powered by” another company on our behalf.

iv. Security detection, protection and enforcement; functionality debugging, error repair:

As part of our efforts to keep our Sites safe and secure;
To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Sites, for example, by requesting verification information in order to reset your account password (if applicable);
To ensure the physical security of our premises through the monitoring of surveillance images; and
To resolve disputes, to protect the rights, safety and interests ourselves, our users or others, and to comply with our legal obligations.

v. Quality control:

To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures; and
To develop and improve our products and services, for example, by reviewing visits to the Sites and various subpages, demand for specific products and services and user comments.

2. Processing Sensitive Personal Information

We collect and process Sensitive Personal Information for the purposes disclosed at the time we collect this information. We do not process or disclose this information for purposes other than the purpose for which it was originally collected unless required by law. The following are permitted purposes under the CPRA:

To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or service;
To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information;
To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions;
To ensure the physical safety of natural persons;
For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business;
To perform services on behalf of our business;
To verify or maintain the quality or safety of products or services that we own or control, and to improve, upgrade, or enhance such products or services; or
To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

3. Disclosing Personal Information

From time to time we disclose your information as described below. This includes disclosing information to our service providers such as professional advisers, lawyers, bankers, staffing partners, auditors and accountants, and, when required by law, to regulators or law enforcement.

A. Disclosure of Personal Information for a Business Purpose.

We may disclose your personal information to service providers and others for a business purpose. The business purposes are listed above. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we may have disclosed the following categories of personal information to service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners; professional advisors); affiliated companies; government regulators; law enforcement; or strategically aligned businesses. This includes Identifiers, Protected personal information, Protected anti-discrimination classification information, Commercial Information, Electronic network activity information, Audio, video or similar information, Geolocation, Professional or employment-related information, Sensitive personal information, and Inferences.

B. Disclosing Personal Information in Sale Arrangements

We do not sell personal information for monetary or other consideration.

C. Sharing Personal Information for Cross-Context Behavioral Marketing

Sharing your personal information means making it available to a third-party so that they can use it to display targeted or cross-context behavioral advertisements to you. Cross-context behavioral or targeted advertising means that we display an advertisement to you that is selected based on personal information about you that we obtained or inferred over time from your activities across other companies’ websites, applications or online services that we use to predict your preferences or interests. Targeted advertising does not include using your interactions with us or information that you provide to us to select advertisements to show you. In the preceding twelve (12) months, we may have shared the following categories of personal information of non-minors for behavioral or cross context or targeted advertising: Identifiers; Protected personal information; Commercial Information; Electronic network activity information; Audio, video or similar information; Geolocation; Sensitive personal information; and Inferences.

4. CPRA Rights.

The CPRA provides California residents with specific rights regarding their personal information. This section describes your CPRA rights.

A. Information Access Rights

As a California resident, you have the right to request that we disclose certain information upon request about our information collection and disclosure practices. You also have the right to request a copy of the specific pieces of personal information we collected about you. You may make Information Access Requests up to twice during a 12 month period. Once we receive and confirm your verifiable request, we will disclose to you:

The categories of personal information we collected about you, the sources of the information, our business or commercial purpose for collecting the information and whether the information was disclosed for a business purpose, shared or sold;
The categories of information we disclosed for a business purpose and the categories of information we sold or shared during the prior 12 months along with the categories of recipients of such information; and
The specific pieces of personal information we collected about you during the prior 12 months, or, at your option, since the applicable calendar year. Please note that this disclosure will not include data generated to help ensure security and integrity or as prescribed by regulation. We will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.

B. Information Deletion Rights

California residents have the right to request that we delete any of the personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm a verifiable request, we will delete (and direct our service providers to delete) the personal information from our records, unless an exception applies. You may make deletion requests at any time. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities and to help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s ability to complete such research, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information;
Comply with a legal obligation; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

C. Information Correction Rights

California residents have the right to request that we correct information that we hold which is inaccurate. We will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections. In some cases, for instance if you have an account with us, you can update your information by logging into your account. You can make information correction requests at any time.

D. Opt-Out Rights

Do Not Sell My Personal Information. We do not sell personal information for monetary or other consideration.
Do Not Share My Personal Information. You have the right to opt out of having your personal information shared with others for cross-context or behavioral advertising purposes. This does not include using your interactions with us or information that you provide to us to select advertisements to show you.
Limit Processing of Sensitive Personal Information. You have the right to tell us not to process or disclose Sensitive Personal Information for any purpose other than the purposes disclosed at or before the time we originally collected it. We only process Sensitive Personal Information for the purpose for which we originally collected it.

5. Exercising Your CPRA Rights

A. Making CPRA Requests

Access, Correction and Deletion. To exercise the access, correction, and deletion rights California residents may contact us by visiting our CPRA request page here or calling us toll-free at 1 833-217-3060. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. Any disclosures we provide will only cover the 12-month period preceding receipt of your request, but you may request that expand the 12-month period to cover information collected since January 1, 2022, and we will honor that expanded request unless doing so would involve a disproportionate effort. We will acknowledge receipt of your request within 10 business days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
Opt-Out Rights. To opt out of the sale of your personal information or the sharing of your personal information or to ask us to limit processing of your Sensitive Personal Information, you may submit a request to us by clicking the following appropriate link: “Do not sell or share my personal information". You may also call us toll free at 1-833-217-3060.
You may also opt out by activating a user-enabled global privacy control, such as a browser plug-in or privacy setting, device setting, or other mechanism, that communicates or signals your choice to opt-out of the sale and sharing of personal information. When we receive such a signal we will stop setting third party, analytics, or advertising partner cookies on your browser. This will prevent the sale or sharing of information relating to that specific device through cookies to our advertising or analytics partners. This option does not stop all sales or sharing of your information because we cannot match your device’s identification or internet protocol address with your personally identifiable information like your name, phone number, email address or ZIP Code and we may have arrangements with other companies that qualify as a sale where your identifiable information, such as your name or email address, is disclosed. If you delete cookies on your browser, any prior do not sell or do not share signal is also deleted and you should make sure that your user-enabled setting is always activated.
We will comply with your request promptly, and at least within 15 business days. Once we receive your request we will wait at least 12 months before asking you to reauthorize personal information sales or sharing.

B. Using an Authorized agents

You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorized the person to make the request on your behalf, (4) you verify your own identity directly with us and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

6. Non-Discrimination

We will not discriminate against you as a result of your exercise of any of these rights. Unless permitted by the CPRA, we will not:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

7. Retention of Personal Information

We will store personal information in a form which permits us to identify consumers, for as long as necessary for the purpose for which the personal information is processed. We may retain and use such personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. We retain information consumers provide in connection with requests made under the CPRA for a period of two years.

11. Notice to Nevada Residents

We do not transfer personal information for monetary consideration. If you would like to tell us not to sell your information in the future please email us at privacy@joinbranded.com with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line.

12. Notice to European and United Kingdom Residents

For the purposes of the UK Data Protection Act 2018 (the “DPA”), the EU General Data Protection Regulation 2016/679 (the “GDPR”), and the GDPR as it applies in the UK by virtue of the European Union (Withdrawal) Act 2018 (the “UK GDPR”) and other laws globally, we are the “controller” and are responsible for deciding how Personal Information is used, collected, and processed, unless expressly specified otherwise. Our details are: Branded ServiceCo, LLC, a Delaware limited liability company, 228 Park Ave S, PMB 78816, New York, New York 10003-1502. By using or accessing the Site, or by providing Personal Information to us on or through the Site, you acknowledge that you have read and understood the policies and procedures described in this Privacy Policy. This Privacy Policy does not apply to the practices of third parties that we do not own or control, or to individuals that we do not employ or manage.

For European Economic Area (“EEA”) and UK residents only. Under EEA and UK data protection law, in certain circumstances, you have the right to:

Request access to any Personal Information we hold about you (“Subject Access Request”) as well as related information, including the purposes for processing the Personal Information, the recipients or categories of recipients with whom the Personal Information has been shared, where possible, the period for which the Personal Information will be stored, the source of the Personal Information, and the existence of any automated decision making;
Obtain without undue delay the rectification of any inaccurate Personal Information we hold about you;
Request that Personal Information held about you is deleted;
Prevent or restrict processing of your Personal Information; and
Request transfer of Personal Information directly to a third party where this is technically feasible.

Also, where you believe that we have not complied with its obligation under this Privacy Policy or UK or EEA law, you have the right to make a complaint to a UK or an EU Data Protection Authority, such as the UK Information Commissioner’s Office.

You can exercise any of these rights by contacting us using the details under “Contacting us” below.

We aim to respond to requests made by you within one (1) month, but may extend that period by two (2) further months where necessary.

13. Data Retention

We will store your Personal Information, in a form which permits us to identify you, for no longer than is necessary for the purpose for which the Personal Information is processed. We may retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. Consistent with these requirements, we will try to delete your Personal Information quickly upon request.

14. Links to other sites

We may permit others to link to this Site or to post a link to their site on ours. We do not endorse these sites and are not responsible for other sites or their privacy practices. Please read their privacy policies before submitting information.

15. Changes to the Privacy Policy

As we grow and change we may amend this Privacy Policy. We may also amend this Privacy Policy to reflect changes in the legal or commercial landscape in which we operate. The Privacy Policy in effect at the time you use the Site governs how we may use your information. If we make material changes we will post the revised version of this Privacy Policy and the revised effective date on this Site. Please check back here from time to time to review any changes.

16. Contacting us

You can contact us using the Contact Us page or by email at privacy@joinbranded.com.