The Sutton Concepts LLC  website available at https://www.suttonconcepts.com, the Sutton Concepts LLC  mobile application, and the various content, features, and services offered on and in connection with these sites, including literature requested or software downloaded by you (collectively, the “Sites and Services are owned and operated by Sutton Concepts LLC, (hereinafter referred to as “we,” “us,” or “Sutton Concepts”). As part of our service to you, we strive to offer visitors of the Site the many advantages of Internet technology and to provide an interactive and personalized experience. In order to do so, we may obtain certain personal information from you. The purpose of this privacy policy (“Privacy Policy”) is to inform you about the types of information we gather about you when you visit the Sites and Services, how we may use that information, and the choices you have regarding our use of that information. This Privacy Policy supplements and is incorporated as a part of the Sutton Concepts Website and Mobile Application Terms of Use available here or by emailing support support@suttonconcepts.com

 

1. MODIFCIATION OF THIS PRIVACY POLICY

Sutton Concepts reserves the right, at its sole discretion, to alter this Privacy Policy at any time effective upon posting the modified Privacy Policy on and in connection with the Sites and Services, with or without additional notice to you, including to comply with privacy laws, regulations and/or our own or industry standards or otherwise. We encourage you to review this Privacy Policy each time you visit our Sites and Services as you are responsible for regularly reviewing information posted on the Sites and Services to obtain timely notice of such changes, and if you do not agree to the amended Privacy Policy, you agree to immediately stop using the Sites and Services and to provide Sutton Concepts notice to remove you from any distribution lists or other communication list that are available to you through your use of the Sites and Services. YOUR CONTINUED USE OF THE SITES AND SERVICES AFTER SUCH POSTING (OR OTHER NOTIFICATION, IF ANY) MEANS YOU ACCEPT AND AGREE TO BE BOUND BY THE MODIFIED PRIVACY POLICY.

 

2. COLLECTION AND USE OF INFORMATION FROM USERS

We collect information on our Users in various ways, including by your voluntary submissions and through “cookie” (as explained  below) and other tracking technology. The information we collect is used in a variety of ways including, but not limited to: fulfilling and providing services requested by you; improving the Sites and Services; notifying you about updates to the Site; and/or informing about products, services and promotions in which you may have interest. With your authorization or as otherwise permitted under this Privacy Policy, we may also share the information you provide with third parties.

 

3. PERSONALLY IDENTIFIABLE INFORMATION

Personally Identifiable Information refers to information that tells us specifically who you are, such as your name, phone number, email, postal address, geospecific data, or credit card information, and possibly information relating to certain support or customer service issues (each, “Personally Identifiable Information”). You generally do not need to provide us with Personally Identifiable Information to use this Sites and Services or to obtain information from much of the features on the Sites and Services. In some cases, however, you may be asked to provide Personally Identifiable Information in order to purchase products through the Sites and Services; access certain services or functions of this Sites and Services; use or subscribe to certain online products or services on the Sites and Services; or to allow us to provide you with certain personalized or enhanced services that you have requested. How we collect and store information depends on the page you are visiting, the activities in which you elect to participate, and the services provided. As noted, you can visit many pages on our Sites and Services without providing any Personally Identifiable Information; however, other pages may prompt you to provide Personally Identifiable Information. If you do not want to provide us with any Personally Identifiable Information, you can always decide not to use such services or access such pages on the Sites and Services. The choice is yours.

 

4. AGGREGATE INFORMATION

From time to time, we may collect general, non-personal, statistical information about the use of the Sites and Services, such as how many visitors visit a specific page on the Sites and Services, how long they stay on that page, and which hyperlinks, if any, they click on. This information represents a generic overview of our Users’ collective viewing habits and allows us and other third parties to modify information, promotions, offers and/or discounts on products and services based on user traffic and behavior. We collect this information through the use of technologies such as “cookies”, which are discussed in greater detail in this Privacy Policy. We collect this information in order to determine which areas of the Sites and Services are most popular and to enhance the Sites and Services for visitors. We may also group this information into aggregate visitor data in order to describe the use of the Sites and Services to our existing or potential business partners or other third parties, or in response to a government request. From time to time, we may use this information to optimize third-party offers of products and/or services. We also may share aggregated demographic and preference data with third parties to enable the provision of targeted information, promotions, offers and/or discounts on products and services. However, please be assured that this aggregate data will in no way personally identify you or any other visitors of the Sites and Services.

 

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

Like most websites, the Sites and Services also may collect information automatically and through the use of electronic tools that may be transparent to Users. For example, Sutton Concepts may automatically collect non-personally identifiable information and data through the use of “cookies.” Cookies are small text files a website uses to recognize repeat Users, facilitate the User’s ongoing access to the website and facilitate the use of the website. Cookies also allow a website to track usage behavior and compile site usage information that will allow for the improvement of content and target advertising. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set your browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. However, please be aware that some features of our Sites and Services may not function or may be slower if you refuse cookies. You may occasionally get cookies from our advertisers or other third parties with links on the Sites and Services as described below. We do not control these cookies. The use of advertising cookies sent by third party ad servers is standard in the Internet industry.

 

Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our Sites and Services is accessed. An IP address is a number that is automatically assigned to your computer whenever you are surfing the web. Web servers, the computers that “serve up” web pages, automatically identify your computer by its IP address. We may link the information we record using tracking technologies to Personally Identifiable Information we collect at the Sites and Services for our own and our marketing partners’ marketing and advertising purposes consistent with the terms of this Privacy Policy. In addition, we reserve the right to use IP addresses and other tracking technologies to identify a visitor when we feel it is necessary to enforce compliance with our Terms of Use, to protect our Sites and Services, our customers or others, or when we believe in good faith that the law requires it.

 

The Sites and Services may also use technology called “tracer tags”. These may also be referred to as “Clear GIFs” or “Web Beacons”. This technology allows us to understand which pages you visit on the Sites and Services. These tracer tags are used to help us optimize and tailor our Sites and Services for you and other Users of our Sites and Services.

 

We may also use third-party advertising companies to serve ads when you visit our Sites and Services. These companies may use information (not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, you can begin by clicking here: http://www.networkadvertising.org/consumer/opt_out.asp.

 

6. DISCLOSURES AND TRANSFERS OF INFORMATION

We do not disclose Personally Identifiable Information to third parties, except when one or more of the following conditions is true. You have authorized us to provide such information, including, but not limited to, “opting-in” to a particular service, program or promotion;

          a.      The disclosure is permitted by relevant law;

          b.      The disclosure is reasonably related to the sale or other disposition of all or part of our business or assets;

          c.      The Personally Identifiable Information to be disclosed is publicly available;

          d.      The party to whom the disclosure is made controls, is controlled by, or is under common control with Sutton Concepts;

          e.      The disclosure is reasonably necessary for the establishment or maintenance of legal claims; or

          f.      The disclosure is to persons or entities that provide services to us, provided the disclosure is consistent with the                                purpose for which the personal information was obtained.

 

7. AS A SERVICE TO OTHERS

We may provide your Personally Identifiable Information to third parties for their marketing and/or advertising purposes, but only if you have authorized us to do so by “opting-in” to a particular marketing or advertising service, program or promotion. Users of our Sites and Services are given the opportunity to affirmatively consent (opt in) to the disclosure of Personally Identifiable Information to a third party or to the use of such information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the User. We do this to ensure that our Users can make an informed choice as to whether or not they want to share their information with such outside parties. We will provide individuals with a reasonable mechanism to exercise their choices.

 

If you have at some point authorized us to share such information about you with others and later properly notify us that you no longer want us to share your information (as discussed below), we will cease sharing your information in this manner. However, except as otherwise stated in this Privacy Policy, we do not control the third parties with whom we share such information and you will need to further notify such third parties if you would like them to cease use of your information.

 

8. OUR SERVICE PROVIDERS

We may sometimes use other businesses to perform certain services for us, such as hosting or maintaining our Sites and Services, storing your information, processing orders or subscriptions, or providing marketing assistance and data analysis. We may provide Personally Identifiable Information to service providers when that information is necessary for them to complete a requested transaction or otherwise perform their duties. Sutton Concepts will take reasonable steps to ensure that these service providers are notified of their obligations to reasonably protect Personally Identifiable Information on Sutton Concepts behalf.

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9. BUSINESS TRANSFERS

As we continue to develop our business, we may buy other businesses or their assets or sell some or all of our business assets.Personally Identifiable Information and other customer information is generally one of the business assets involved in such transactions. Thus, in the event that Sutton Concepts or all of its assets are acquired, such information may be one of the transferred assets.

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10. PROTECTION OF COMPANY AND OTHERS

Sutton Concepts fully cooperates with law enforcement agencies in identifying those who use our services for illegal activities, and may in its sole discretion disclose Personally Identifiable Information or other information to satisfy any law, regulation, subpoena, or government request or in connection with litigation. Sutton Concepts reserves the right to release Personally Identifiable Information or other information about Users who we believe are engaged in illegal activities or are otherwise in violation of our Terms of Use, even without a subpoena, warrant or court order, if we believe in our sole discretion that such disclosure is necessary or appropriate to comply with any laws, to operate the Sites and Services, or to protect the rights or property of Sutton Concepts LLC, its affiliates, or any of their officers, directors, or employees, agents, third party content providers, suppliers, sponsors, or licensors. Sutton Concepts also reserves the right to report to law enforcement agencies any activities we reasonably believe in our sole discretion to be unlawful.

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11. DATA SECURITY AND INTEGRITY

We take reasonable precautions to protect the privacy, accuracy, and reliability of any information you provide and to protect such information from loss, misuse, unauthorized access, disclosure, alteration and destruction. The Personally Identifiable Information you provide and we collect is stored within databases that we control directly or through our service providers. As we deem appropriate, we use security measures consistent with industry standards, such as firewalls and encryption technology, to protect your information. However, since no security system is impenetrable, we cannot guarantee the security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. As a result, you transmit any information to or from the Sites and Services at your own risk.

 

12. ACCESSING AND DELETING PERSONALLY IDENITIFIABLE INFORMATION; OPT-OUT

If you have submitted Personally Identifiable Information through the Sites and Services and you would like access to such information, please send an email to support@suttonconcepts.com. We will use reasonable efforts to supply you with this information and to correct any factual inaccuracies that you identify. Please also contact us at support@suttonconcepts.com.if you do not want us to disclose your Personally Identifiable Information to third parties or you want us to delete your Personally Identifiable Information from our databases. Keep in mind, however, that there may be residual information within our databases, access logs and other records, which may or may not contain such information. The residual information will not be used for commercial purposes; however, we reserve the right, from time to time, to re-contact former Users of this Sites and Services.

Notwithstanding any other provision of this Policy, we reserve the right to send you certain non-promotional communications to fulfill pending or ongoing services requested by you, relating to the Sites and Services (such as service announcements), email related to purchases you have made or information you have submitted, or similar administrative or transactional messages.

 

13. AFFILIATED SITES, LINKED SITES AND ADVERTISEMENTS

Sutton Concepts LLC expects its partners, advertisers and third-party affiliates to respect the privacy of our Users. However, third parties, including our partners, advertisers, affiliates and other content providers accessible through our Sites and Services, may have their own privacy and data collection policies and practices. For example, during your visit to our Sites and Services you may link to, or view as part of an Sutton Concepts page, certain content that is actually created or hosted by a third party. Also, you may be introduced to, or be able to access, information, websites or advertisement features offered by other parties through the Sites and Services. Sutton Concepts is not responsible for the actions or policies of such third parties. You should check the applicable privacy policies of those third parties when providing information on a feature or page operated by a third party.

Please be careful and responsible whenever you are online. Should you choose to voluntarily disclose Personally Identifiable Information on our Sites and Services, such as completing an online form request or email link, that information can be viewed publicly and can be collected and used by third parties without our knowledge and may result in unsolicited messages from other individuals or third parties. Such activities are beyond the control of Sutton Concepts and this Privacy Policy.

 

14. CHILDREN

We understand and share your concerns regarding your children’s access to Internet and the Internet’s access to your children. Consistent with the Children’s Online Privacy Protection Act of 1998 (COPPA), we do not knowingly request or accept Personally Identifiable Information submitted to the Sites and Services by any visitor under 13 years of age. If we become aware that an individual under age 13 has provided information to Sutton Concepts LLC through the Sites and Services, we will not use or disclose that individual’s information for any purpose unless required to do so by law.

 

15. DO NOT TRACK SIGNALS

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently is NOT an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

 

16. CONTACTING US

Sutton Concepts welcomes your feedback and questions about the Sites and Services. However, any comments, ideas, notes, messages, suggestions, or other communications sent to the Sites and Services shall be and remain the exclusive property of Sutton Concepts and Sutton Concepts may use all such communications in any manner, including reproducing, disclosing and publishing such communications, all without compensation or notice to you. Any communication or material you transmit to the Sites and Services by electronic mail or otherwise is, and will be treated as, non-confidential and non-proprietary. Feedback and comments should be sent to support@suttonconcepts.com.

 

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Revised 4.16.19