Privacy Policy

Last Updated: April 10, 2023

1. Introduction

PLEASE READ THIS PRIVACY POLICY ("POLICY") CAREFULLY TO UNDERSTAND HOW WE COLLECT, USE, AND TREAT YOUR PERSONAL INFORMATION THROUGH THE USE OF OUR WEBSITES, MOBILE APPLICATIONS, AND THROUGH EMAIL, TEXT, AND OTHER ELECTRONIC COMMUNICATIONS BETWEEN YOU AND PT INTERMEDIATE HOLDINGS IV, LLC, AS WELL AS YOUR CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE WEBSITES, APPLICATIONS, OR COMMUNICATE THROUGH EMAIL, TEXT, OR OTHER ELECTRONIC COMMUNICATIONS.

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PT Intermediate Holdings IV, LLC and its affiliates and subsidiaries (including the PT Intermediate Holdings IV, LLC subsidiaries in the USA and in Canada) (collectively, "Encompass Supply Chain Solutions," "Genuine Replacement Parts," "Eldis Group" or also referred to herein as the "Company" or "we") is committed to protecting the privacy and security of the information we collect, use, share, and otherwise process as part of our business. We respect your privacy and are committed to protecting it through our compliance with this policy. We also believe in transparency, and are committed to informing you about how we treat the information we collect and process.

This Policy describes the types of information we may collect from you or that you may provide when you visit top-level domain websites (each, a "Website", collectively the "Websites"), or as otherwise set forth herein, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect:

on our Websites;
through mobile applications you download from application stores (like Google Play® and the Apple App Store®) which provide dedicated non-browser-based interaction between you and our Websites ("Apps");
in email, text, and other electronic messages between you and our Websites ("Messaging"); and
when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

This Policy does not apply to information collected by:

The Company offline or through any other means, including on any other website operated by the Company or any third-party; or
any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites, Apps, or Messaging modalities. By accessing or using these Websites, Apps, or Messaging modalities you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of these Websites, Apps, and Messaging modalities after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

Privacy Principles

When processing personal information, the Company will follow these principles in compliance with applicable law including, but not limited to, the EU General Data Protection Regulation 2016/79 ("GDPR"), the Canadian Personal Information Protection and Electronic Documents Act ("PIPEDA"), the CCPA, CPRA, and State Privacy Laws (as those terms are more fully defined in this Policy, and other applicable data privacy and security laws:

The Company endeavors to inform persons whose Personal Information the Company collects, in accordance with applicable law, when those persons are first asked to provide personal information to the Company, or as soon as practicable thereafter. This includes, as more fully set forth in this Policy, providing information about (i) the purposes for which the Company collects and uses the Personal Information, (ii) the types of third parties to which the Company discloses (or may disclose) that Personal Information, and (iii) the choices and means the Company offers the subjects of the Personal Information for limiting the use and disclosure of their Personal Information.
Unless permitted by applicable law, no Personal Information is collected without first obtaining the appropriate consent of the individual for the collection, use and disclosure of that Personal Information, in accordance with applicable data privacy laws. In some circumstances the consent for the Company to collect Personal Information may arise from the nature of the relationship between the Company and the individual, or an individual’s interaction with the Company, such as by using a the Company website or engaging in a transaction with the Company.
The Company will collect your Personal Information only for specified and legitimate purposes as set forth in this Policy. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected.
The Company will process your Personal Information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented.
The Company will take commercially reasonable steps to ensure that your Personal Information is reliable for its intended use, accurate, complete, and, where necessary, kept up to date.
The Company will not use your Personal Information for direct marketing purposes without giving you an opportunity to "opt-out," which is more fully described in this Policy.
The Company will take appropriate measures, by contract or otherwise, to provide adequate protection for Personal Information that is disclosed to a third party or transferred to another country, including transfers within the Company, as more fully set forth herein.
When you provide Personal Information to the Company, or otherwise access or use the Websites, Apps, or Messaging modalities, you acknowledge that you have read this Policy and, where required under applicable law, consent to the collection, use and disclosure of your Personal Information in accordance with this Policy and other applicable the Company policies. You may, as provided by applicable law, be free to refuse or withdraw your consent, as more fully described herein.
the Company, and third parties on its behalf, as more fully set forth herein, use the Personal Information collected from you for purposes such as, but not limited to, user registration; administering and tracking a purchase, payment, return, warranty; arranging for services; inviting participation in online surveys; requesting feedback on products and services; and otherwise communicating with you through various channels.

2. Data Controller, Data Protection Officer, and Representative

The Company is the data controller of the Personal Data you provide on the Websites. The Company has appointed a Data Protection Officer, as identified in Section 22 of this Policy.

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The Company is the data controller of your Personal Data. The Company has appointed a Data Protection Officer and a representative in the European Union in compliance with the General Data Protection Regulation. The Company, its Data Protection Officer, or its representative may be contacted in any manner set forth below in the "Contact Information" Section of this Privacy Policy.

3. Children Under the Age of 18

Our Websites are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Websites. We will remove any information about a child under the age of 18 if we become aware of it.

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The Children’s Online Privacy Protection Act ("COPPA"), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. The Websites are restricted to the use of adults over the age of majority in their place of residence. No portion of the Websites is directed to children under the age of 18, and no one under the age of 18 may access, browse, or use the Websites or provide any information to or on the Websites. Consequently, we do not knowingly collect Personal Information from any person under the age of 18. If we learn that we have collected Personal Information from a child under age 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete that information as quickly as possible. If you are a parent or guardian of a child under 18 years of age and you believe your child has provided us with Personal Information, please contact us at [email protected] for such information collected by a the Company subsidiary.

For more information about COPPA, please visit the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

4. Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

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We collect several types of information from and about users of our Websites, specifically information:

by which you may be personally identified, such as your name, billing information, home, work, and/or shipping addresses, work or personal e-mail address, telephone number(s), credit or debit card number (for payment processing only), Federal Tax ID (if you claim that you are tax exempt), your voice (only for audio feedback), or any other identifier by which you may be contacted online or offline ("Personal Information");
that is about you but individually does not identify you, such as your employer name, title, account number, traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites, error information, clickstream data, and other communication data and the resources that you access and use on the Websites;
about your internet connection, the equipment you use to access our Websites, and usage details.

We collect this information:

directly from you when you provide it to us;
automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies, as described more fully in the "Our Use of Cookies and Other Similar Technologies" section of this Policy as well as in our Cookie Policy, which can be accessed here.

Information You Provide to Us The information we collect on or through our Websites are:

information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Websites or requesting further services. We may also ask you for information when you enter promotions sponsored by us, and when you report a problem with our Websites;
your voice recording when you choose to leave us audio feedback;
records and copies of your correspondence (including email addresses), if you contact us;
your responses to surveys that we might ask you to complete for research purposes;
details of transactions you carry out through our Websites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Websites; and
your search queries on the Websites.

The Personal Information we collect from you is required to enter into a contract with the Company, for the Company to perform under the contract, and to provide you with our products and services. If you refuse to provide such Personal Information or withdraw your consent to our processing of Personal Information, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

details of your visits to our Websites, specifically traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites, error information, clickstream data, and other communication data and the resources that you access and use on the Websites; and
Information about your computer and internet connection, specifically your IP address, operating system, and browser type.

The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Websites and to deliver a better and more personalized service by enabling us to:

estimate our audience size and usage patterns;
store information about your preferences, allowing us to customize our Websites according to your individual interests;
speed up your searches; and
recognize you when you return to our Websites.

Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie Policy.

Our Websites use cookies and other similar technologies to provide you with our Websites and their features, to improve the functionality of our Websites, to measure and track how you interact with the Websites, to perform analytics, to track ad-driven activity, to provide you with advertising based on your use of our Websites and your interests, and to otherwise tailor our communications with you. These cookies may be served by us or by third parties we use to help us maintain and provide you with our Websites. You can disable our use of these cookies and other similar technologies by changing your browser settings, however our Website may not function correctly if you select this setting.

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For more information, see our Cookie Policy.

6. Lawful Basis for Processing Your Personal Data

We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.

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If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

By using our Websites, you consent to our collection, use, and sharing of your Personal Data as described in this privacy policy. If you do not consent to this privacy policy, please do not use the Websites;

Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Specifically, our legitimate interests are to: facilitate communication between the Company and you; detect and correct bugs and to improve our Websites; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other financial crime; promote and market our business; check your credit and perform risk assessments; develop our services; to assist original equipment manufacturers address maintenance and support issues; and

To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our Contract with you to deliver our goods and services to you. Specifically, we process your Personal Data to provide you with the products that you order from us. We may also disclose your Personal Data to equipment manufacturers and original equipment manufacturers so that they can assist in fulfilling your order.

As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspection, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

7. Special Categories of Information

We generally do not request you provide and do not process any special categories of Personal Information or Sensitive Personal Information (as that term is defined in the California Privacy Rights Act).

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The Company does not ask you to provide, and we do not knowingly collect, any special categories of Personal Information from you or Sensitive Personal Information (, including Personal Information that reveals your racial or ethnic origin, political opinions, religious, philosophical beliefs, or trade unions membership, or the processing of data concerning your health or data concerning your sex life or sexual orientation or history of criminal convictions.

8. Automated Decision Making

We generally do not use your Personal Information with any automated decision-making processes.

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The Company does not use your Personal Data with any automated decision-making process, except for limited fraud detection and avoidance.

9. How We Use Your Information

We use your Personal Information for various purposes described below, including to:

provide our Websites to you;
provide you with information you request from us;
enforce our rights arising from contracts;
notify you about changes; and
provide you with notices about your account

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We use information that we collect about you or that you provide to us, including any Personal Data:

to present our Websites and their contents and functionality to you;
to provide our operations and services to you;
to communicate with you and provide you with information, products, or services that you request from us;
when necessary to fulfill transaction requests, via phone;
to respond back to you via SMS messaging, if you send us a question via SMS messaging;
to follow up on your satisfaction with purchases made on the Websites;
to improve our services and develop new services;
to assist original equipment manufacturers in fulfilling your order and addressing maintenance and support issues;
to fulfill any other purpose for which you provide it;
to provide you with notices about your account;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to manage our relationship with you and your use of the Websites;
to notify you about changes to our Websites or any products or services we offer or provide though them;
to allow you to participate in interactive features on our Websites;
to register you for our email list and send you periodic messages;
to engage with you on social media;
to enable you to share comments, questions, and answers;
to improve our marketing efforts, including by providing more tailored advertising;
to ensure the privacy and security of our Websites and services;
to maintain our databases and back-ups, including records of our communications with you;
to recognize your device and remember your preferences and interactions;
to determine and track user interests, trends, needs, and preferences;
for general operational support, including procurement, financial and fiscal management, risk and compliance management, and reporting;
to facilitate corporate mergers, acquisitions, reorganizations, dissolutions, or other transactions;
to obtain and maintain insurance coverage and professional advise;
to comply with federal, state or local laws;
to comply with a civil, governmental, or regulatory inquiry, order, subpoena, summons, or process;
to cooperate with law enforcement agencies;
to exercise or defend legal rights or claims;
to create, use, retain, or disclose de-identified or aggregated information;
in any other way we may describe when you provide the information; and
for any other purpose with your consent.

We may also use your Personal Information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you wish to opt-out of this use, please check the relevant box located on the form on which we collect your Personal Information. If you wish to change your choice, you may do so at any time by logging into the Websites and adjusting our user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected] for such information sent by a the Company subsidiary. For more information, see Choices About How We Use and Disclose Your Information.

10. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Information for purposes other than those outlined in this Policy. We disclose your Personal Information (excluding the phone numbers collected through the SMS channel) to a few third parties, including:

our subsidiaries and our affiliates;
our contractors, third-party service providers and advisors that we use to support our business;
to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
to comply with our legal obligations;
to enforce our rights; and
with your consent.

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We do not share, sell, or otherwise disclose your Personal Information for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Information that we collect or you provide as described in this Policy:

to our subsidiaries and affiliates, and their respective officers, directors, employees, and agents;
to contractors, service providers, professional advisers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. Specifically, these entities provide customer service, IT and infrastructure support, payment processing, marketing, and shipping services, as well as accounting and legal services. Our payment processor’s privacy policies may be found at https://www.cybersource.com/privacy/
to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company Supply Chain Solutions’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company about one or more of our Websites’ users is among the assets transferred;
to fulfill the purpose for which you provide it. For example, if you give us an email address to contact us about a question, we will use your email address to respond back to you;
to original equipment manufacturers to fulfill your order and address maintenance and support issues;
for any other purpose disclosed by us when you provide the information; and
with your consent.

We may also disclose your Personal Information:

in response to subpoenas, warrants, court orders or other legal process, including to respond to any government or regulatory request, or to comply with relevant laws. We may also share information in order to establish or exercise our legal rights or claims; to defend against a legal claim; and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contracts or terms;
to enforce or apply the Terms and Conditions on our Websites and other agreements, including for billing and collection purposes; and
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our affiliates, subsidiaries, customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

For more information, see Choices About How We Use and Disclose Your Information.

11. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for third-parties to advertise to you, our advertising to you, and other targeted advertising.

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We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with control over your Personal Information:

Promotional Offers from the Company. We may use your contact information to promote our own or third parties’ products and services. If you wish to opt-out of such use, you can check the relevant box located on the form on which we collect your Personal Information or otherwise seek such consent. If you wish to change your choice, you may do so at any time by logging into the Websites and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may click the unsubscribe link at the bottom of the email to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
Targeted Advertising. We may use information that we collect or you provide to deliver advertisements according to our and our advertisers’ target-audience preferences. If you wish to opt-out of such use, you can check the relevant box located on the form on which we collect your Personal Information or otherwise seek such consent. If you wish to change your choice, you may do so at any time by logging into the Websites and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected]. For this opt-out to function, you must have your browser set to accept browser cookies.
Disclosure of Your Information for OEM Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email with your request to [email protected]

12. Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.

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Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.

Access and Update. You can review and change your Personal Data by logging into the Websites and visiting the "My Account" page. You may also notify us through the contact information below or through our Websites’ live chat features between 8 AM and 9 PM EST of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing, but we have retained it as permitted by law.
To the extent the Personal Data you provide the Company is processed based on your consent, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods below and through the live chat feature of our Websites. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements.

13. Do Not Track Signals

We may use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.

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We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they "do not track" your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such signal is broadcast or received.

14. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Information. You can help protect your Personal Information and other information by keeping your password to our Websites confidential.

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We have implemented measures designed to secure your Personal Information under our control from accidental loss and from unauthorized access, use, alteration, and disclosure. From time to time, we review our security procedures and consider new technologies and methods.

Our payment processors are contractually obligated to encrypt any payment transactions using SSL technology in order to keep your payment information safe. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, no security system is perfect and no data transmission is 100% secure. Although we strive to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to or from our Websites. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites. We cannot guarantee that your Personal Information will remain secure in all circumstances.

Systems and processes have been scrutinized for limiting access to only required personnel, and the proper protections and restrictions to physical accessibility have been implemented to secure your Personal Information from accidental loss and from unauthorized access, use, alteration or disclosure. We use reasonable security measures when transmitting Personal Information to consumers in responding to requests under the California Consumer Privacy Act or other applicable laws.

If a data breach compromises your Personal Information, we will notify you and any applicable regulator when we are required to do so by applicable law.

15. California Residents

Notice at Collection. For purposes of the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), in collecting the information described above, we collect the categories of Personal Information listed below.

CCPA Category	Description
Identifiers	When collecting Account Information, we will receive your name, email address, username, and unique personal identifier. When collecting Social Media Information, Feedback or Support Inquiries, and Contact Us Data, we will receive your name and email address. When collecting Social Media Information, we will receive your name and email address. When collecting Cookies and Similar Technologies and Usage Information, we will receive your Internet Protocol (IP) address or unique device identifier. We use Identifiers as set forth in the "Information We Collect About You and How We Collect It," the "How We Use Your Information," and the "Disclosure of Your Information" sections of this Policy.
Categories of personal information described in the California Customer Records statute	When collecting Account Information, we will receive your name, email address, username, and unique personal identifier. When collecting Social Media Information, Feedback or Support Inquiries, and Contact Us Data, we will receive your name and email address. When collecting Social Media Information, we will receive your name and email address. When collecting Cookies and Similar Technologies and Usage Information, we will receive your Internet Protocol (IP) address or unique device identifier. We use Categories of Personal Information described in the California Customer Records statute as set forth in the "Information We Collect About You and How We Collect It," the "How We Use Your Information," and the "Disclosure of Your Information" sections of this Policy.
Internet or other electronic network activity information	We collect Cookies and Similar Technologies as described in our "Cookies and Similar Technologies" Policy. When collecting Usage Information, we will automatically receive information from your browser and your device, which includes the date and time of your visit as well as your location, Internet Protocol (IP) address, domain server, browser type, access time, and data about which pages you visit. We use Internet or Other Electronic Network Activity Information as set forth in the "Information We Collect About You and How We Collect It," the "How We Use Your Information," and the "Disclosure of Your Information" sections of this Policy.
Geolocation data	When collecting Cookies and Similar Technologies, Location Information and Usage Information we will receive your location while using the Site. We use Geolocation Data as set forth in the "Information We Collect About You and How We Collect It," the "How We Use Your Information," and the "Disclosure of Your Information" sections of this Policy.
Audio, electronic, visual, thermal, olfactory, or similar information	When collecting Contact Us Data, we will receive your preferred method of contact and the message that you choose to provide. We use Audio, electronic, Visual, Thermal, Olfactory, or Similar Information as set forth in the "Information We Collect About You and How We Collect It," the "How We Use Your Information," and the "Disclosure of Your Information" sections of this Policy.
Commercial Information	We use Commercial Information as set forth in the "Information We Collect About You and How We Collect It," the "How We Use Your Information," and the "Disclosure of Your Information" sections of this Policy.
Professional or employment-related information	When collecting Account Information and Contact Us Data, we will receive your work email address, work telephone number, company name, and company address. We use Professional or Employment-Related Information as set forth in the "Information We Collect About You and How We Collect It," the "How We Use Your Information," and the "Disclosure of Your Information" sections of this Policy.
Inferences	Examples: Derivation of information, data, assumptions, or conclusions from facts, evidence, or another source of information or data) drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Data Practices During Last 12 Months

Personal Information Collected: As described in this Policy, we have collected the categories of Personal Information listed below during the preceding 12 months:<

Identifiers

Categories of personal information described in the California Customer Records statute
Characteristics of protected classifications
Commercial information
Biometric information
Internet or other electronic network activity information
Audio, electric, visual, thermal, olfactory, or similar information
Professional or employment-related information
Inferences drawn from other Personal Information to create consumer profiles
Geolocation data

Categories of Sources: We have collected the Personal Information identified in this Policy from you directly when you provide it to us, automatically as you navigate through the Websites, which may include, but not be limited to, usage details, IP addresses, and information collected through cookies and other tracking technologies, and from our business partners, as applicable.

Business and Commercial Purposes for Collecting: We have collected the categories of Personal Information listed above for the following purposes:

Operate the Websites;

Provide our services to you;
Honor our terms of use and contracts;
Ensure the privacy and security of our Websites and services;
Maintain our databases and back-ups;
Manage our relationships with you;
Communicate with you;
Keep records of our communications with you;
Analyze use of the Websites and our services;
Serve you the content and functionality you request;
Develop new services;
Enhance your experience;
Track visits to the Websites;
Provide you with a more personal and interactive experience on the Websites; and
Usage analytics purposes.

Personal Information Sold or Shared: We have not sold or shared categories of Personal Information during the preceding 12 months.

Personal Information Disclosed for a Business Purpose. We have disclosed for a business purpose the categories of Personal Information listed below during the preceding 12 months:

Identifiers
Categories of personal information described in the California Customer Records statute
Characteristics of protected classifications
Commercial information
Biometric information
Internet or other electronic network activity information
Audio, electric, visual, thermal, olfactory, or similar information
Professional or employment-related information
Inferences drawn from other Personal Information to create consumer profiles
Geolocation data

We have disclosed each category of Personal Information to the following categories of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (accountants, attorneys); (3) service providers (data analytics, data storage, mailing, marketing, website and platform administration, technical support); and (4) operating systems and platforms.

Children

The Company does not collect or maintain Personal Information on any minors under the age of 16. We do not knowingly sell or share Personal Information of minors under 16 years old, however, to the extent we knowingly "sell" or "share" as that term is defined under the CCPA and the CPRA, respectively, the Personal Information of minors under 16 years old who are California residents, we either obtain prior affirmative authorization from such minor to the opt-in to the sale of the minor’s Personal Information or obtain affirmative authorization from the minor’s parent or guardian. A minor, or parent/guardian, who has opted in to the sale of the minor’s Personal information has the right to opt-out at any time. To exercise your right to opt-out see the Right to Opt-Out section above. See also the Verified Requests to Know and Right to Delete with regard to Personal Information of any minors under the age of 16.

Personal Information Retention

We will store your personal information for as long as is reasonably necessary to fulfill the purposes described in this Privacy Policy or as required by law.

Right to Opt Out/Do Not Sell My Personal Information

Under the CCPA and CPRA, you have the right to direct us to stop selling and sharing your Personal Information to third parties and to refrain from doing so in the future. To the extent we sell or share your Personal Information, as those terms are defined in the CCPA and CPRA, respectively, you have the right to opt-out of the sale or sharing of your Personal Information at any time. You may submit a request to opt-out here or by contacting or us at [email protected]. For purposes of the CCPA and CPRA, we do not sell or share Personal Information as defined under applicable law.

Requests to Know and Requests to Delete

The CCPA and CPRA give consumers the right to request that we (1) disclose what Personal Information we collect, use, disclose, sell, and share and (2) delete certain Personal Information that we have collected or maintain. You may submit these requests to us as described below, and we honor these rights where they apply.

If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (1) treat the request as if it had been submitted in accordance with the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.

Request to Know.

As a California resident, you have the right to request: (1) the specific pieces of Personal Information we have collected about you; (2) the categories of Personal Information we have collected about you; (3) the categories of sources from which the Personal Information is collected; (4) the categories of Personal Information about you that we have sold or shared and the categories of third parties to whom the Personal Information was sold or shared; (5) the categories of Personal Information about you that we disclosed for a business purpose and the categories of third parties to whom the Personal Information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, or selling Personal Information; and (7) the categories of third parties with whom we sell or share Personal Information. Our response will cover the 12-month period preceding our receipt of a verifiable request, except as otherwise required by applicable law.

Request to Delete.

As a California resident, you have a right to request the erasure/deletion of certain Personal Information collected or maintained by us. As described herein, we will delete your Personal Information from our records and direct any service providers (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.

Request to Correct.

As a California resident, you have a right to request the correction of certain inaccurate Personal Information collected or maintained by us. Upon receipt of a verifiable request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct the inaccurate Personal Information as directed by you, pursuant to applicable law.

Right to Limit Use and Disclosure Sensitive Personal Information.

As a California resident, you have a right to request that use and disclosure of Sensitive Personal Information be limited to that use which is necessary to perform the services or provide the goods reasonably expected by a similarly situated consumer and as authorized in accordance with applicable law. You further have the right to opt-out of the selling or sharing of your Sensitive Personal Information. See the Right to Opt-Out section for further instructions as to how to Opt-Out.

Submitting a Request

Submission Instructions. You may submit a request to know or to delete here or by email to [email protected]. Regarding requests to delete, we may present you with the choice to delete select portions of your Personal Information, but a global option to delete all Personal Information will be offered and more prominently presented.

Verification Process.

We are required by law to verify the identities of those who submit requests to know or to delete. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, account number, address, and telephone number. We will inform you if we cannot verify your identity.

If we cannot verify the identity of the person making a request for categories of Personal Information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our Policy.

If we cannot verify the identity of the person making the request for specific pieces of Personal Information, we are prohibited from disclosing any specific pieces of Personal Information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.

If we cannot verify the identity of the person making a request to delete, we may deny the request.

If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.

Authorized Agents.

Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require you to: (1) provide the authorized agent with signed permission to do so; (2) verify your identity directly with us; and (3) directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code.

Excessive Requests.

If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

Time Period to Comply with Requests.

The Company will disclose and deliver the required information as requested by you pursuant to this Section 15 free of charge, correct inaccurate personal information, or delete your personal information, based on your request, within 45 days of receiving a verifiable request, but will confirm receipt of your request within 10 business days of receipt of same. We will promptly take steps to determine whether the request is a verifiable consumer request, as set forth herein, but this shall not extend our duty to disclose and deliver the information, to correct inaccurate personal information, or to delete personal information within 45 days of receipt of the request. However, the time period to provide the required information, to correct inaccurate personal information, or to delete personal information may be extended once by an additional 45 days when reasonably necessary, provided we provide you with notice of the extension within the first 45-day period.

Non-Discrimination

You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA and CPRA. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers for exercising their rights under the CCPA or CPRA.

Statistical Metrics California Shine the Light

Under California Civil Code Section 1798.83, California residents who provide Personal Information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your Personal Information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at [email protected]

16. Nevada Residents

You may submit a verified request to us at [email protected] to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law. However, please know that we do not currently sell data triggering the Nevada statute’s opt-out requirements.

17. Colorado, Connecticut, Virginia, and Utah Residents

If you are a resident of Colorado, Connecticut, Utah or Virginia, you may have certain privacy rights under the applicable privacy laws in your state ("State Privacy Laws"). This section describes those rights and how you can exercise them with the Company.

Rights Requests Right to Know, Right to Deletion and Right to Correct

You can request what Personal Information we have collected, used, disclosed, and sold.

You can request to correct inaccuracies in your Personal Information, taking into account the information’s processing purpose.

You can opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects including, but not limited to, automated processing performed on personal information to evaluate, analyze or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location or movements ("Profiling"). To submit a request to opt out pursuant to this section, please contact us using the information provided in the Contact Information section of this Policy. To opt out of cookie-based or digital advertising-based Profiling, please opt out of the selling/sharing of your information for targeted advertising, as described above. Note that if you opt out of profiling, your experience with the Company will be less personalized.

We will not be able to opt you out of Profiling where one of the following exceptions applies:

Legal:

To comply with applicable laws, rules or regulations; to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by governmental authorities; to cooperate with law enforcement; to investigate, exercise, prepare for or defend actual or anticipated legal claims; or to assist another party with any of its obligations under applicable laws;

Security:

To prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, or malicious, deceptive, or illegal activity; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;

Improvement of Services and Products/Internal Use:

To conduct internal research to improve, repair or develop products, services or technology;

Transactional:

To provide a product or service specifically requested by you; to complete a transaction with you or to complete a contract we have with you; and

Public Interest:

To protect your vital interests or those of another individual.

You can also request that we delete your Personal Information. We may not delete all of your Personal Information if one of the following exceptions applies:

Transactional:

To complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or perform a contract we have with you;

Security:

To detect data security incidents; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;

Error Correction:

To debug or repair any errors;

Legal:

To protect against fraud, harassment, malicious or deceptive activities, or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; to assist another party with any of its obligations under applicable privacy laws; or

Internal Use:

To use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e., to improve our services).

Right to Appeal

If you are a Colorado, Connecticut or Virginia resident and we were unable to fulfill your request, you may appeal our request by contacting us using the information provided in the Contact Information section of this Policy within fourteen days of our decision, and submitting an appeal request, with a detailed reason for your appeal, as well as your state of residence.

Retention

We will store your personal information for as long as is reasonably necessary to fulfill the purposes described in this Privacy Policy or as required by law.

To exercise any of these rights or to appeal a decision regarding a consumer rights request, please contact us using any of the methods listed in Contact Information section of this Policy.

18. Consent to Processing of Personal Data In Other Countries Outside the European Economic Area

We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.

Read More

In order to provide our Websites, products, and services to you, we may send and store your Personal Data outside of your home country, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an adequate level of protection for your Personal Data.

Your Personal Data is transferred by the Company to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using our Websites, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Websites.

If you are in the European Economic Area, to ensure your Personal Data (other than Personal Data you provide directly to us on our Websites) is treated in accordance with this Privacy Policy, the Company uses Data Protection Agreements between the Company and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the "Standard Contractual Clauses"). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third party. You may request a copy of the Data Protection Agreement by contacting us through the contact methods below.

19. Data Retention Periods

We retain your Personal Information for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:

on our backup and disaster recovery systems;
for as long as necessary to protect our legal interests; and
to comply with other legal requirements.

Read More

The Company will retain your Personal Information for the entire time that you keep your account open. After you close your account, we may retain your Personal Information:

for as long as necessary to comply with any legal requirement;
on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

We may delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our objectives or legal obligations. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.

We are required by law to maintain records of consumer requests submitted under the California Consumer Privacy Act and how we responded to such requests for at least twenty-four (24) months. We only use this information for recordkeeping purposes. If you are a resident of California, please see the California Residents section for more information.

20. Third-Party Sites

This Policy only applies to the Websites. It does not apply to any websites, applications, or services from third parties.

The Websites may include links to, or content from, third parties. These links are to external resources and third parties that have their own privacy policies. It may not always be clear which links are to external, third-party resources. If you click on a third-party link, you will be redirected away from the Websites. You can check the URL to confirm whether you have left the Websites.

We cannot and do not (1) guarantee the privacy or security practices of third parties or any content provided by third parties; (2) control third parties’ collection or use or your information; or (3) endorse any third-party information, products, services, applications, or websites.

Any information provided by you or collected from you by a third party will be governed by that party’s privacy policy and terms of use. You should review their privacy policy and terms of use carefully.

21. Changes To Our Privacy Policy

We will post any changes to our Privacy Policy on our Websites. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

Read More

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Websites’ home page. Any changes, updates, and modifications will be effective immediately upon posting. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Websites’ home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this Privacy Policy to check for any changes. Your continued use of the Websites after the "Last Updated" date will constitute your acceptance of and agreement to any changes and to our collection, use, and sharing of your information according to the then-current Policy. If you do not agree with this Policy, you should not use the Websites.

22. Contact Information

You may contact our Data Protection Officer through the contact information below. If you wish to contact us, you must contact both us and our representative through the contact information below or through the "Contact Us" page on our Websites.

Read More

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you must contact both us and our representative in the European Union at the contact information below or through the "Contact" page on our Websites.

To Contact the Company (Controller)
Encompass Supply Chain Solutions, LLC
775 Tipton Industrial Drive, Suite F
Lawrenceville, GA 30046 USA
USA: 877.918.9645
Canada: 866-344-1792
For The Company in the USA: [email protected]
For The Company in Canada: [email protected]

To Contact Our Data Protection Officer
Alberto Valedon
1200 Greenbriar
Addison, IL 60101 USA
USA: 877.918.9645
Canada: 866-344-1792
[email protected]

23. Text Messaging

You may opt-in to receive electronic communications (including voice messages, push notifications, or text messages) on your mobile device. When you opt-in, we will send you an SMS message to confirm your registration to receive these communications.

You may cancel receiving these communications at any time by texting STOP one of our text messages. We will respond to a STOP request by confirming that you have been unsubscribed. If you would like to resume these communications, simply login to your account on our Website and re-register for such communications.

If you would like help regarding these communications, you may also text the word HELP to us for help. We will respond to this request with instructions on how to use our electronic communications services and how to unsubscribe. You may also email us at [email protected] or call us 1-630-866-4385.

We are able to deliver messages to most major cell phone carriers. If you have any question regarding our ability to deliver messages to your carrier, please contact us via the Website and we can confirm whether our electronic communication service supports your carrier.

Message and data rates may apply for any messages you send to us or you receive from us. You will receive updates at each state of an order delivery, including a confirmation of you placing the order, when it has been shipped, and package tracking information (including, when the package has been delivered). If you have any questions about your text plan or data plan, please contact your cell phone provider.

You understand the text messages we send may be seen by anyone with access to your phone. Accordingly, you should take steps to safeguard your phone and your text messages if you want them to remain private. Please notify us immediately if you change mobile numbers or plan to provide your phone to another person. For questions about the services provided through our electronic communications system or about your privacy, please contact us through one of the ways described above. You may find more information about our privacy policy here

We may terminate our text message program at any time.

Privacy Policy

1. Introduction

2. Data Controller, Data Protection Officer, and Representative

3. Children Under the Age of 18

4. Information We Collect About You and How We Collect It

5. Our Use of Cookies and Other Similar Technologies

6. Lawful Basis for Processing Your Personal Data

7. Special Categories of Information

8. Automated Decision Making

9. How We Use Your Information

10. Disclosure of Your Information

11. Choices About How We Use and Disclose Your Information

12. Your Rights Regarding Your Information and Accessing and Correcting Your Information

13. Do Not Track Signals

14. Data Security

15. California Residents

16. Nevada Residents

17. Colorado, Connecticut, Virginia, and Utah Residents

18. Consent to Processing of Personal Data In Other Countries Outside the European Economic Area

19. Data Retention Periods

20. Third-Party Sites

21. Changes To Our Privacy Policy

22. Contact Information

23. Text Messaging