PRIVACY POLICY

Effective Date: February 17, 2024

Retail Solutions, LLC respects the privacy of our website visitors and customers. We believe it is important that you understand the kinds of data we collect about you, how we protect that data, and how it is used. We recognize the need for appropriate safeguards and management of Personal Information you provide to us. This Privacy Policy (“Policy”) sets forth the privacy principles Retail Solutions follows with respect to your Personal Information we collect from or about you, either online through this website, or any of the products, services, interactive features, forms, social media pages offered, owned, or operated by Retail Solutions, or its affiliates, or your interaction with Retail Solutions service providers, contractors or employees (collectively “Services”), whether accessed online via computer, tablet, mobile device or any other technology or device now known or hereafter developed, or offline, and how your Personal Information will be used. The Services are intended for use by individuals residing and located in the United States.

When we reference “Personal Information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with you, directly or indirectly. Personal Information does not include information that cannot be reasonably linked to you.

This Policy covers all Personal Information (information that relates to or that can be used to identify you) by Retail Solutions at its website https://retailsolutions1.com (the “Site”). This Policy does not describe information collection policies and practices of websites and platforms that we do not provide, own, or control, including those linked to or integrated with our Site. It also does not cover information you may choose to share with other users of the Site. We encourage you to review this Policy periodically. Your use of the Site constitutes your consent to the terms contained herein. We will periodically update this Policy, and any changes will be reflected here. We will notify existing customers of any material changes by email or via your account.

If you have any questions about this Policy or how we use your Personal Information, please feel free to contact us at emailprivacy@retailsolutions1.com.

Table of Contents

What Personal Information Do We Collect?

When using the Retail Solutions Site, we may collect information you voluntarily share with us, including any content, record, or electronic communication of any kind, including without limitation:

• contact information, including identifiers such as name, full shipping address, country of residence, phone number, username, password, and email address.

• financial information related to payment or requested credit account, including name, email address, billing address, credit card information, banking information, telephone number, Social Security number (for example to establish a credit account and track available credit) and other information necessary to complete a transaction or purchase.

• commercial information, such as a record of products or services purchased, and the date and time the transaction occurred.

• information you submit or choose to provide when you send us a message through the “Contact Us” page, any chatbot, customer service representative, or similar features on the Site and other information that you choose to provide during your interaction(s) with use.

• inferences, such as product and service preferences including your preference in receiving marketing information received from our third parties, product feedback, and survey responses.

• internet information, such as IP address, GPS, login data, browser, time zone, geographical location and any other unique identifier (a set of numbers or characters assigned to your computer, mobile phone or other device used when you are on the internet) tied to your device when visiting our Site, and information about how you use and interact with our Site.

The period for which we retain your personal information varies, depending on the type of personal information and the purpose for which it was collected. For example, we retain your order information for as long as you are a customer to ensure that you have access to your order history. The retention duration is limited to time necessary to fulfill the purposes for which the information was collected, in light of any restrictions or deletions you might request, as well as our need to address our legal obligations for rights. Please see Your California Privacy Rights below for more information.

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How Do We Collect Your Personal Information

When You Interact with Us

We may collect your Personal Information when you interact with the Site, including but not limited to when you:

• make a purchase on the site
• subscribe to emails / newsletters
• request services or seek support
• participate in promotions and surveys
• give feedback about products, services, or website

Cookies, Web Beacons, and Other Technologies

• automated technologies or interactions
• cookies, pixel tags, embedded scripts, LSOS, Priority Code

Cookies are stored on your computer’s hard drive and identify your web browser and the activities of your computer on the Site and other websites. Most browsers accept cookies automatically, but you may disable them. Cookies help us facilitate efficient Site navigation, improve your experience on the Site, facilitate your shopping session, allow us to take note of visits to the Site and show relevant ads on our Site and across the Internet.

Action tags, also known as web beacons or single pixel GIFs, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you. Any portion of the Site, including advertisements or emails sent on our behalf, may contain action tags. Action tags can be used to count Site users, to deliver services, or to determine whether email messages have been opened or acted upon. Action tags may be used to conduct research on behalf of certain clients, to compile statistics for advertising purposes, for auditing purposes, or to report certain aggregate information.

By using these identifiers together, we are able to gather information to improve the Site and measure the effectiveness of our advertising and marketing campaigns. Embedded URLs perform many of the same functions as cookies and we may utilize them as a tracking tool to collect Non-Personal Information. Embedded URLs are exhibited as plain text or encoded extensions to the URL that appear in the browser address or location toolbar. They provide limited Non-Personal Information about navigation on the Site during the current session.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can obtain information about blocking and deleting cookies from your browser’s settings. You may also manage preferences regarding cookies by visiting https://allaboutcookies.org/manage-cookies/.

From Third Parties

We may collect information from our third party providers, including but not limited to:

• analytics providers
• advertising networks
• identity verification services
• credit reporting agencies (as applicable)
• payment & delivery services

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How Does Retail Solutions Use the Personal Information We Collect?

We may use your Personal Information:

To provide the Site to you, including:

• to determine whether our services are available in your country;
• to determine your preferred language;
• to process your registration and account creation with the websites, including verifying your contact information is active and valid;
• to identify you as a user in our system;
• to process transactions you initiate, process payments and provide accurate billing and shipping; and
• to improve our website, product and service offerings, and develop new products and services.

To communicate with you, including:

• to provide you with information, products or services that you have requested or agreed to receive;
• to send you administrative e-mail, such as order confirmations, order status updates, security, or support and maintenance advisories;
• to bill you for products or services
• to notify you about changes to our service;
• to contact you with regard to your use of the Site and, in our discretion, changes to the Site’s policies or functionality; and
• to send you informational and transactional text messages that you have requested or agreed to receive.

To personalize your experience on the Site and Platform, including:

• to customize our Site and its contents to your interests and your device;
• to customize and tailor your experience on the Site, for example, by displaying content that we think you might be interested in; and
• to improve the quality of experience when you interact with our Site for internal business purposes.

To comply with our legal obligations and protect our other users, including:

• for compliance, fraud prevention and safety, including enforcing our terms of service and this Privacy Policy, protecting our rights privacy, safety, or property and/or that of you or others, and protecting against, investigating or deterring fraudulent, harmful, unauthorized, unethical or illegal activity;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
• to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• to perform other functions as described at the time of collection, with your consent, or as further described in this Privacy Policy.

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Your Choices

OPT-OUT OR UNSUBSCRIBE TO MARKETING MESSAGES

We do not send any direct marketing emails unless you opt-in. You may choose to opt-in to receive direct marketing emails on the Site In the future, if you do not wish to have your e-mail address or other contact information used for promotional purposes, you should visit the Retail Solutions opt-out policy on web form.

Please note that we reserve the right to send you certain communications relating to your account (for example, administrative and service announcements, shipping notices, and order confirmations) and these transactional account messages may be unaffected if you opt-out from marketing communications from Retail Solutions.

CHOOSING NOT TO SHARE PERSONAL DATA

You may choose not to provide us with any Personal Information. In such an event, you may still be able to access and use some portion of the Site; however, you may not be able to access and use those portions that require your Personal Information.

Where we need to collect Personal Information by law, or under the terms of a contract we have with you or are trying to enter with each other and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

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Children's Information

The Site are not directed to children under the age of 18. We do not knowingly collect any personal information from children under the age of 18. If we learn that a child under the age of 18 has provided us with personal information, or that such personal information has otherwise been inadvertently collected, we will delete it in accordance with applicable law.

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Who Do We Share Your Information with?

Service Providers and Contractors. As part of Retail Solutions’s operation of its Site, we may contract with third-party providers to perform certain functions, including fulfilling orders, processing payments, and customer service. These third parties may have access to Personal Information to the extent necessary to permit them to assist Retail Solutions in performing the functions set forth above. Any such third party that processes your information for these purposes shall agree to do so in accordance with our instructions and in accord with this Policy.

Merger, Sale or other Transaction. We may disclose information about you to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or disposition of all or a portion our assets. The successor organization’s use and disclosure of your personally-identifiable information will continue to be subject to this policy unless (i) a court orders otherwise, for example a bankruptcy court; or (ii) the successor organization gives you notice that your Personal Information will be subject to the successor organization’s own policy, along with an opportunity for you to opt out (which may cause you not to be able to continue to use our Services). If you submit Personal Information after such a transfer, that information may be subject to the successor entity’s policy.

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Third Party Sites

Third-Party Sites may contain links to other sites. Please be aware that Retail Solutions is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave the Site and to read the privacy statements of each and every website. This Privacy Policy applies solely to information collected by Retail Solutions Site.

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Categories of Information We Collect

We have collected the following categories of information in the past 12 months:

1. Category of Personal Information: Contact information (including identifiers such as name, full shipping address, country of residence, phone number, username, password, and email address).

• Sources of This Personal Information: You and identity verification services.
• How We Use This Personal Information: To fulfill your orders, process your account registration, and communicate with you.
• Categories of Third Parties We Share This Information with: Service providers and contractors.

2. Category of Personal Information: Financial information (including billing address, credit card information, banking information, telephone number and other information necessary to complete a transaction or purchase).

• Sources of This Personal Information: You and credit reporting agencies.
• How We Use This Personal Information: To process your payments.
• Categories of Third Parties We Share This Information with: Service providers and contractors.

3. Category of Personal Information: Commercial information (including record of products or services purchased, and the date and time the transaction occurred).

• Sources of This Personal Information: You and our payment and delivery services.
• How We Use This Personal Information: To process our orders and comply with our legal obligations.
• Categories of Third Parties We Share This Information with: Service providers and contractors.

4. Category of Personal Information: Inferences (including marketing, product, and service preferences).

• Sources of This Personal Information: You, analytics providers, and advertising networks.
• How We Use This Personal Information: To personalize the site for you.
• Categories of Third Parties We Share This Information with: Service providers and contractors.

5. Category of Personal Information: Internet information (including IP address, GPS, login data, browser, time zone, geographical location, and any other unique identifier used to identify you or your device).

• Sources of This Personal Information: Cookies and other technology, and analytics providers.
• How We Use This Personal Information: To personalize the site for you.
• Categories of Third Parties We Share This Information with: Service providers and contractors.

6. Category of Personal Information: Social Security number.

• Sources of This Personal Information: You
• How We Use This Personal Information: To establish a credit account and track available credit.
• Categories of Third Parties We Share This Information with: Service providers and contractors.

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Security

To prevent unauthorized access or disclosure, to maintain data accuracy, and to allow only the appropriate use of your Personal Information, we utilize industry standard physical, technical, and administrative controls and procedures to safeguard the information we collect. However, you should recognize there is always some risk involved in the transmission of information over the internet or in a method of electronic storage.

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Consent to Transfer

The Retail Solutions Site is operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using our Site, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

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U.S. State Privacy Rights

I. Disclosure of Personal Information

We disclose personal information to our service providers and contractors, as described in this Privacy Policy.

Retail Solutions does not and will not sell the Personal Information of consumers. In the preceding twelve (12) months, Retail Solutions has not sold Personal Information.

II. Your Rights and Choices

This United States (U.S.) Privacy Notice (“Notice”) is for people living in the United States and supplements our Retail Solutions Privacy Policy, which explains how we collect, use, and disclose your Personal Information.

This Notice describes your privacy rights and how to exercise your rights under the Colorado Privacy Act, the Connecticut Act Concerning Personal Information Privacy and Online Monitoring, the Utah Consumer Privacy Act, the Virginia Consumer Data Protection Act, the Oregon Consumer Privacy Act, the Texas Data Privacy and Security Act, and the Montana Consumer Data Privacy Act. We call those laws collectively the “U.S. Privacy Laws.” For California Privacy Rights, please refer to the California Notice at Collection.

If you are a resident of a state that has laws that govern our processing of your Personal Information, you may have certain rights, as provided under the state law applicable to you, subject to certain exemptions, which may include the:

• Right to Know (All Listed States): The right to request that we disclose to you the Personal Information that we collected or disclosed about you including:

- The categories and specific pieces of Personal Information we have collected about you;

- The categories of the sources of the Personal Information;

- The purposes for which your Personal Information is collected and used;

- The categories of Personal Information that the business disclosed for a business purpose, and for each category identified, the categories of third parties to whom that particular category of Personal Information was disclosed; and

- The categories of Personal Information that the business sold or shared, and for each category identified, the categories of third parties to whom that particular category of Personal Information was sold or shared;

• Right to Access/Data Portability (All Listed States): Access, request and receive, up to twice every 12 months, a portable copy of the Personal Information that we have collected about you in the last 12 months;

• Right to Correct (All Listed States Except Utah): The right to request that we correct inaccuracies in your Personal Information that we maintain about you;

• Right to Request Deletion (All Listed States): The right to request that we delete or erase Personal Information we have collected about you, subject to certain exemptions;

• Right to Limit the Use and Disclosure of Sensitive Personal Information (CA): The right to direct us to limit our use of your sensitive Personal Information to that use which is necessary to perform the services or provide the goods as reasonably expected by someone who requests those goods or services and for business purposes allowed by law;

• Right to Opt-In for Sensitive Data Processing (CO, CT, MT, OR, TX and VA): The right to opt-in for the use of sensitive Personal Information, which may include race, ethnicity, precise geolocation data, minor information, and certain health data.

• Right to Opt-Out (All Listed States – except UT residents do not have the right to opt out of automated decision making): The right to opt-out of or object to having your Personal Information sold to, or shared with, third parties for the purposes of targeted advertising or to process your personal data for profiling or automated decision making in furtherance of decisions that produce legal or similarly significant effects on you; and

• Right to Non-Discrimination (All Listed States): The right not to be discriminated against by us for exercising any of these rights.

• Right to Appeal (All Listed States): The right to submit an appeal if your request is denied.

Additional Privacy Rights

California

California residents may have additional personal information rights. Please see Your California Privacy Rights below for more information.

Nevada

Nevada residents have certain privacy rights as specified under Nevada law. Our Privacy Policy and the privacy controls we offer to all users are in line with these laws—this notice assures we cover the Nevada-specific requirements.

Do Not Sell Notice: We do not sell your covered information, as defined under Chapter 603A of the Nevada Revised Statutes. If you still have questions about your covered information or anything else in our Privacy Policy, please contact us using the contact information below.

Your California Privacy Rights

Effective Date: January 1, 2020

Amendment Effective Date: January 1, 2023

This Privacy Notice for California Residents supplements and is expressly made part of the information contained in the Retail Solutions Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). Any terms defined in the CCPA or CPRA have the same meaning when used in this Notice.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA, as amended by the CPRA, rights and explains how to exercise those rights.

Right to Access Your Information

You have the right to request that Retail Solutions disclose what personal information we have collected used or disclosed over the past 12 months.

Right to Request Deletion

You have the right to request that Retail Solutions delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Consumer Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Right to Opt Out

You have the right to opt-out of both the sale and sharing of personal information for cross-context behavioral advertising; opt-out of automated decision-making/profiling technology in connection with decisions with significant or legal effects; and opt-out of the processing of sensitive personal information.

Right to Access Information About Automated Decision Making

You have the right to request that Retail Solutions provide information about the logic involved in automated decision-making and a description of the likely outcome of the process.

Right to Correct Information

You have the right to request that Retail Solutions correct your personal information if it is inaccurate.

Right to Limit Sensitive Personal Information

You have the right to limit Retail Solutions’s use and disclosure of sensitive information to information that is necessary to perform the services or provide the goods reasonable expected by an average consumer who requests such goods and services.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA, as amended by the CPRA, rights.

Other California Privacy Rights

California’s "Shine the Light" law (Civil Code § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

Exercising Your Rights

You or your authorized agent may submit a request to exercise your rights by visiting web form or calling us at 1-833-508-3301. For your security and to ensure unauthorized third parties do not access your Personal Information, we will require you to verify your identity before we can act on your request. If you are a current customer or still have access to your Retail Solutions account, you will be required to authenticate through your Retail Solutions account. If you do not have an account with us, you will be required to provide an email address and mobile phone number to start the verification process. You may also be required to provide a qualified government-issued photo identification. If you are asking for access on behalf of someone else, we will require verification of your identity, as well as proof of authorization by the individual whose Personal Information you wish to access.

Authorized Agents

If you are a resident of a state that has laws that govern our processing of your Personal Information and would like to designate an authorized agent to submit certain requests on your behalf, or if you are an authorized agent of an individual with the right to submit certain requests via an authorized agent and would like to submit a request on behalf of that individual, please send an email to the following email address: emailprivacy@retailsolutions1.com. If you are the resident, in order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such request. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you are the authorized agent, after you submit the request, and if the request is not subject to an exemption or exception, we will require additional information to verify the identity of the resident, as well as your authority to act on behalf of the resident.

Appeals

If we did not take action on your request, and if you are a resident of a state that offers a right to an appeal, you may have the right to appeal our decision. To submit an appeal, use the Request to Appeal option on web form. Please note that an appeal must be submitted within 60 days of your receipt of the notice to take action.

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Your EU and UK Privacy Rights

This Section applies to residents of the EU or the UK, and supplements and is expressly made part of the information contained in Retail Solutions, LLC.’s Privacy Policy.

As detailed below, to the extent provided by the law of your jurisdiction, you may have legal rights in relation to the personal information about you that Retail Solutions holds. We may require you to verify your identity if you request this information.

Lawful basis for processing your personal data.

We process on the following legal bases:

1. Contract: It is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract.

2. Legitimate Interests: We process your personal data if it is based on our legitimate interests. For example, we may process personal data in reliance on a legitimate interest in the effective and lawful operation of our business, the effective delivery and improvement of our products, services, and platforms, information security operations, compliance with laws and regulations, compliance with requests for disclosure to law enforcement, courts, and regulatory bodies, and to prevent and detect fraud or suspected fraud. In relation to general inquiry and complaints you send us, our legitimate interest is to provide you with information you have requested and to provide customer support. You can object to the processing that we carry out on the grounds of legitimate interests. See the section “Rights of data subjects” below to find out how.

3. Consent: Where you have given us consent to do so, we provide you, or permit third parties to provide you, with information about goods or services which we feel may interest you. You have the right to withdraw your consent. Please see the section “Rights of data subjects” below to find out how.

4. Legal Claims: We need to process your personal data to defend or establish a legal claim (for example, claims relating to the sale of our goods and services under contract law).

Rights of data subjects

You have the following rights, where provided under applicable law, regarding your information (each of which are subject to various exceptions and limitations):

1. The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Policy.

2. The right of access: You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Policy). This is so you are aware and can check that we are using your information in accordance with data protection law.

3. The right to rectification: You are entitled to have your information corrected if it is inaccurate or incomplete.

4. The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

5. The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

6. The right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services and platforms.

7. The right to object: You have the right to object to certain types of processing, in particular processing based on our legitimate interests. You also can object at any time to your information being used for direct marketing purposes (including profiling related to such direct marketing). Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

8. The right to refuse or withdraw consent: You have the right to refuse to provide and withdraw your consent to processing of your personal information at any time with effect for future processing.

Request to Enact Rights

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Data Protection Commission in Ireland (DPC): https://forms.dataprotection.ie/contact

Please note your rights in relation to your personal data are not absolute. We may, for example, deny you access to your personal data when required or authorized by law, or if granting access would have an unreasonable impact on another individual’s privacy. We will retain and use your personal information as described in this Policy, including as necessary to comply with our legal and business obligations, resolve disputes, and enforce our agreements.

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Right to Modify this Privacy Policy

We reserve the right to modify this Privacy Policy at any time at our sole discretion. If we modify the Privacy Policy, we will post the revised Policy here, with an updated revision date. Changes will be effective immediately (except for material changes) upon the posting of the revised Privacy Policy on the Site. In the event we make material changes to this Privacy Policy, we will notify you through the Services prior to the changes taking effect. Please note that if you do not agree to the modified Privacy Policy, you may not use the Services. Your continued use of the Services following the posting of the changes or any applicable notice period will mean that you accept those changes.

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Contact Us

If you have any questions or comments about this Policy, the practices or use of the Site, please feel free to contact us by phone at +1 833-508-3301; by email at emailprivacy@retailsolutions1.com; or by mail to the following address: 8 Thornton Road, Oakland, NJ 07436, Attn: Privacy Office.

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