Privacy Policy

This Privacy Policy describes how TrustBo and affiliates (collectively, “TrustBo,” “we,” “us,” or “our”) collects, uses, shares, and safeguards personal information. The "affiliates" referred to in this privacy policy includes concepts such as TrustBo and such other affiliates as we may acquire or launch from time to time. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions. You can jump to particular topics by going to the headings below:

Types Of Information We Collect
Use And Processing Of Information
Cookies
Sharing Of Information
Your Choices
Authorized Agent
Annual Data Requests
How We Protect Personal Information
Other Important Information
Contact Information

Types Of Information We Collect

The following provides examples of the type of information that we collect from you and how we use that information.

Context	Types of Data	Primary Purpose for Collection and Use of Data
Account Registration	We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account.	We use this information to provide account related function-alities to our users. Accounts can be used for easy checkout and to save your preferences and transaction history.
Client Information	We collect the name, and contact information, of our clients, affiliates, and their employees with whom we may interact.	We have an interest in contacting our clients and communi-cating with them concerning normal business administration such as projects, services, and billing.
Cookies and First Party Tracking	We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our Cookie Section below for more information.	We use this information to ensure our website operates efficiently.
Cookies and Third Party Tracking	We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. See our Cookie Section below for more information.	Where required by law, we base the use of third party cookies upon consent.
Demo-graphic Information	We may collect personal information, such as your age, location, and gender.	We use this information to comply with applicable laws.
Email Inter-connectivity	If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.	We use this information to understand how you interact with our communic->ations to you.
Employ-ment	If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.	We use information about current employees to carry out our payment and benefits obligations. In some contexts, we are also required by law to collect information about our employees. We also use this information to have efficient staffing and work force operations.
Feedback/Support	If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.	We use this information in order to receive, and act upon, your feedback or issues.
Mailing List	When you sign up for one of our mailing lists we collect your email address or postal address.	We share information about our products and services with individuals that consent to receive such information. We also use this information to share information about our products or services.
Mobile Devices	We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or when visiting one of our stores.	We use this information to identify unique visitors and understand how users interact with us on their mobile devices.
Order Placement	We collect your name, billing address, shipping address, e-mail address, phone number, and credit card number when you place an order.	We use your information to perform our contract to provide you with products or services.
Partner Promotion	We collect information that you provide as part of a co-branded promotion with another company.	We use this information to fulfil our promotions.
Surveys	When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.	We use this information to understand your opinions and collect information relevant to our organization.
Sweep-stakes or Contests	When you participate in a sweepstakes or contest we collect information about you which includes contact information to notify you if you are selected.	We use this information to operate the sweepstakes. In some contexts we are also required by law to collect information about those that enter into our sweepstakes.
Website Interactions	We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.	We use this information to understand how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.
Web Logs	We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.	We use this information to monitor our networks and the visitors to our websites. Among other things, it helps us understand which of our products or services is the most popular.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.

Use And Processing Of Information

In addition to the purposes and uses described above, we use information in the following ways:

• To identify you when you visit our websites or our stores.
• To provide products and services or to process returns.
• To improve our services and product offerings.
• To streamline the checkout process.
• To conduct analytics.
• To respond to inquiries related to support, employment opportunities, or other requests.
• To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.
• For internal administrative purposes, as well as to manage our relationships.
• To manage your employment application, assess your qualifications, and manage your employment with us.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you complete an online purchase we may collect your information to perform our contract with you, but we also collect your information so that we can quickly and easily respond to any questions about your order.

Cookies

What are cookies? A cookie is a small file placed onto your device that enables a variety of features and functionality. Cookies also enable you to easily share content and help us serve relevant ads to you. Cookies can do this because websites can read and write them, enabling websites to recognize you and remember important information that will make your use of a website more convenient (for example by remembering preference settings). We use cookies and other similar technologies to ensure everyone who uses our website has the best possible experience and for marketing purposes.

How are cookies used for advertising purposes? Cookies and other ad technology such as beacons, pixels, and tags help us serve relevant ads to you more effectively. They also help us provide aggregated auditing, research, and reporting for advertisers, understand and improve our service, and know when content has been shown to you. We may use third party advertising companies to serve ads when you visit our website. These companies may employ cookies and clear GIFs to measure advertising effectiveness. We encourage you to read the privacy policies of these third party advertising companies if you have any concerns. Note: Because your web browser may request advertisements and beacons directly from third party ad network servers, these networks can view, edit, or set third party cookies, just as if you had requested a web page from their site. Ads served by us may also set third party cookies.

Unless you clear these cookies from your browser, we may use this information to:

• provide more relevant, interest-based advertising
• provide aggregate reports of ads activity to advertisers and websites hosting the ads
• help website and app owners understand how visitors engage with their sites or apps
• detect and defend against fraud and other risks to protect users and partners
• improve our products

Controlling cookies. Most browsers allow you to control and erase cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may worsen your overall user experience, since it will no longer be personalized to you. Additionally, some features may work improperly or not at all. It may also stop you from saving customized settings.

Sharing Of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

1. Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
2. Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
3. Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
4. Public. Some of our websites may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publicly available.
5. Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them. Their use of your information is not governed by this privacy policy.
6. Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.

Your Choices

You can make the following choices regarding your personal information:

1. Access To Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
2. Deletion Of Your Personal Information. You may request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
3. Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
4. Promotional Emails You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.

Please address written requests and questions about your rights to support@trustbo.co or call us at 1-800-604-4457. You may submit a copy of the personal information that we hold about you through our online portal, located here.

Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.

If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:

1. A completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf.
2. If you are a business, proof that you are registered with the Secretary of State to conduct business in California.

If we do not receive both pieces of information, the request will be denied.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

Other Important Information

The following additional information relates to our privacy practices:

• Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.
• Changes To This Privacy Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
• Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.
• Information for California Residents. California law indicates that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law). You can find a list of the categories of information that we collect and share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the "Contact Information" section below. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

Effective Date: July 1, 2019

Last Revised Date: July 31, 2020