SUREGUARD PRIVACY POLICY EFFECTIVE MAY 1, 2017

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING A SUREGUARD, OR RELATED WEBSITE, INCLUDING WEBSITES OWNED OR OPERATED BY AFFILIATES, PARENTS, SUBSIDIARIES, DIVISIONS, SUCCESSORS, ASSIGNS AND TRANSFEREES. WEBSITES AFFILIATED WITH ENCORE PRESENTLY INCLUDE “POST GUARD,” “SUREGUARD,” “GLASS CITY PLASTICS, INC.,” AND WEBSITES OPERATED USING D/B/A’S, HEREINAFTER COLLECTIVELY REFERRED TO IN THE SINGULAR AS “SELLER”-OWNED WEBSITE. WHEN YOU USE A SELLER-OWNED WEBSITE, YOU ARE AGREEING TO BE SUBJECT TO THIS PRIVACY POLICY. DO NOT USE ANY SELLER-OWNED WEBSITE OR ANY OTHER SELLER COMMUNICATION POINT AS DESCRIBED BELOW IN THIS PRIVACY POLICY, IF YOU DO NOT WANT TO BE SUBJECT TO THIS PRIVACY POLICY, AS USE OF A SELLER-OWNED WEBSITE CONSTITUES KNOWLEDGE, AND ACCEPTANCE OF THE TERMS OF THIS PRIVACY POLICY.

This Privacy Policy applies to all information received by Seller (hereinafter from time to time referred to either as “Seller,” “we,” “our” or “us”) through various on-line and/or off-line points of communication (collectively, the “Communication Points”), including but not limited to, the following examples of information which you provide:

  1. Information intentionally sent by you to a Seller website (and any other Seller websites), including any of its microsites or subsites (collectively, “Seller Owned Websites”). Seller-Owned Websites are the property of Seller or its licensors;
  2. Information from Seller’s social media pages on Non-Seller Owned Websites, as explained in the Section below entitled “Links to Non-Seller Owned Sites” (e.g., Seller’s official/verified pages on such social media websites, such as Facebook, Twitter, YouTube, Instagram, Google+, Flickr and/or Vimeo, and more), which post a link to a Seller-Owned Website containing this Privacy Policy; and
  3. Information from other electronic, in-person, hard copy, written or other means by which you communicate and may provide us with information, such as when purchasing Products from Seller’s on-line store, using credit cards and/or other third-party payment facilities; by participating in, or using any Seller-related or sponsored promotions, coupons, discounts, membership incentives, or other programs which typically provide a discounted or special price for purchases from Seller, by redeeming a Seller-related issued offer, by communicating with Seller at trade shows or similar events, by registering on a Seller-Owned Website, by making requests for service, and/or by registering your product.

Privacy

Collecting information allows Seller to better understand and to be more responsive to you, your Product preferences, and needs; such information is helpful to develop and maintain websites relevant to your needs, and assists us in more effectively managing our business. To protect privacy, we provide this privacy-related notice explaining our general informational practices and the choices you can make about the way your information is collected and used. In connection with the foregoing and other related objectives, we endeavor to use various commercially reasonable physical, administrative, and technological safeguards to protect the integrity and security of all information collected, including information which we need to share with service providers. While we monitor secure traffic to and from the websites for various purposes, we are not, and cannot guaranty that our websites or any e-commerce activity, is totally secure. Therefore, we encourage website visitors and purchasers to be cautious and take affirmative steps to protect your own information online, including ensuring that your online account information remains secure.

Notice To All Non-U.S. Users

All Seller websites are operated in the United States. If you are located outside of the United States, please be aware that any information provided to us is transferred to the United States, and by using the websites and voluntarily providing your information, you consent to such transfer of information with the understanding that the applicable law(s) in the Unites States may not require provision of private information at the same level of protections as the laws of other countries.

notice to california residents

If you are a California resident, you may, one time per calendar year, request a notice regarding the categories of personally identifiable information disclosed by Seller (if any) during the immediately preceding 12-month period, to third parties for their own direct marketing purposes, and the name and address of any such third parties. To obtain such a notice, please send a written request by postal mail to: Encore Commercial Products, Inc., 37525 Interchange Dr., Farmington Hills, MI 48335 Attention: Website Director

notice to canadian residents

This privacy Policy is written with the intent to address both federal and provincial legislative privacy requirements as recognized in the ten (10) Canadian Standards Association (CSA) Principles incorporated into the Personal Information Protection and Electronic Documents Act (“PIPEDA”). In the event of a conflict with the provisions of this Policy, and any such legislation, the Policy provisions shall apply.

the information we collect

We collect both Non-Personally Identifiable Information and Personally Identifiable Information, each defined below, that you provide to us through the Communication Points.

  1. Non-Personally Identifiable Information is information that cannot be used to identify you or to contact you and is information not associated with a specific personal identity. It includes information that we (or our third party service provider) collect automatically, or passively, from you by tracking your use of the Seller Owned Websites, using technology and methodology that enables tracking, such as cookies, pixels, web beacons, log files and other tracking technologies (collectively, “Cookies”). A Cookie is a small file of information sent by a web server to store on a web browser so it can later be read back from that browser. Information that a Cookie collects may include, but is not limited to, information such as domain type, browser version, service provider, internet protocol address, time spent and web pages visited, as well as information searched for on our Seller Owned Websites. Cookies help a website recognize a returning visitor for purposes of saving certain preferences that the visitor set while previously browsing the website. This tracking through the use of cookies will not by itself reveal anything to us about you personally or provide us with any information that personally identifies you, such as your name, e-mail address or other personally identifiable information. Non-Personally Identifiable Information may also include information that you, at your option, voluntarily provide us through any of the other Communication Points, and includes but is not limited to information such as hobbies and interests, gender, age, level of education, as well as purchases from, and experience with, Seller’s website and Products which are available for purchase.
  2. Personally Identifiable Information is information collected from the Communication Points associated with a person’s name or personal identity, and can be used to identify or contact you. It includes but is not limited to such information as your name, postal address, e-mail address, telephone number (mobile and/or landline), fax number, and credit/debit card information.

    We do not knowingly or purposely collect Personally Identifiable Information from children under the age of thirteen (13). All Products available for sale on Seller’s website are intended to be purchased only by adults. We do not collect or maintain site information via the website or otherwise, from those we actually know are under thirteen (13) years old. If you notify us that information has been provided by or about a child under the age of thirteen (13), upon receipt of written notice and verification, we will promptly delete such information.

how we use collected information

Seller uses collected information (both Personally Identifiable Information and Non-Personally Identifiable Information) to provide you with the goods, services or information that you request, and also to help us better understand the needs and interests of consumers so that we may more closely meet your needs. For example, we may use Personally Identifiable Information to help you complete a transaction or order with us, to respond to your inquiries and requests, to provide and update you on our customer services and support, to notify you of promotional or special offers, to communicate with you about our Products and services, to allow you to participate in an interactive feature, to invite you to participate in surveys about our Products and/or services, to send you information about Seller Products, services, promotions, events, and service advisories, to post reviews or comments that you have submitted to Seller, and/or to help us determine other Seller Products, services or information that may be of interest to you (see the Section below, “Your Privacy Preferences Regarding Personally Identifiable Information-Opting In/Out” regarding sending such communications to you). Personally Identifiable Information in the form of credit/debit card information is used only for payment processing and fraud prevention, and is never retained, except at the specific prior consent of a user.

We use Non-Personally Identifiable Information to increase the functionality and user friendliness of our Seller Owned Websites, to improve the design, content and visitor experience of all of our Communication Points, and/or to deliver interest-based advertising as described in this Privacy Policy (see Section below, entitled “Online Behavioral Advertising” regarding interest-based advertising). We may also use Personally Identifiable Information and/or Non-Personally Identifiable Information for research purposes such as analyzing how visitors use and navigate our Seller Owned Websites. In addition, we may take your Personally Identifiable Information and make it Non-Personally Identifiable Information, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics, such as your name, that make the information personally identifiable to you, i.e., de-personalizing your information. Given the nature of this information, there are no restrictions under this Privacy Policy on Seller’s right to aggregate or de-personalize your Personally Identifiable Information, and use and/or share with third parties the resulting Non-Personally Identifiable Information in any way.

who we share information with

Seller may disclose Personally Identifiable Information to companies affiliated with Seller, such as our affiliated companies and/or generally unaffiliated third parties working on our behalf, for us or with us, such as agents, service providers, consultants, shippers, contractors, vendors and suppliers, for the limited purposes of enabling them to respond to your requests to us, or your purchase of Products, services or information, for fulfilling Seller-related promotions and/or offers, assisting us in understanding your needs and interests so that we can better provide you with Products, services or information, or for the other purposes addressed above entitled “How We Use Collected Information.” All such affiliated and unaffiliated parties who have access to Personally Identifiable Information are required by Seller to keep confidential such information and may not use it for any purpose(s) other than to carry out the services they are performing for Seller and as otherwise required by law. Except as otherwise expressly stated in this Privacy Policy, Seller will not share Personally Identifiable Information with third parties without your permission, unless legally required to (a) comply with any law, subpoena, regulation or court order; (b) respond to requests from governmental authorities; and/or (c) help prevent fraud or to protect the safety, rights, property or security of Seller as well as that of third parties.

links to non-seller owned sites

The Communication Points may include links to and/or from other websites and/or social media platforms which are not owned or controlled by Seller and are owned by companies or parties which are either affiliated or unaffiliated with Seller (collectively, “Non-Seller Owned Websites”). These links are provided to you as a matter of convenience and for informational purposes only. When you access links to or from a Non-Seller Owned Website, you are not on a Seller Owned Website. We do not endorse or make any representations about Non-Seller Owned Websites, and we are not responsible for, and we specifically disclaim all warranties, express or implied, as to the practices, privacy, content, policies, or security of such Non-Seller Owned Websites. You are responsible for reviewing, and we encourage you to review the terms of use, privacy and any other policies of such Non-Seller Owned Websites.

online behavioral advertising

Seller may participate in targeted advertising, whereby you may receive advertisements that may be of interest to you on Seller-Owned Websites and/or Non-Seller Owned Websites from Seller, third party advertisers or advertising networks. These advertisements are selected based on an assessment of your on-line browsing behavior, search activities and/or demographic information. We do not share Personally Identifiable Information for this purpose. If you receive a behaviorally targeted advertisement as stated above, you may click on the icon displayed on the advertisement to receive more information, including instructions for opting out from receiving further advertisements from that particular advertising network. Your opt-out choices may depend on your specific device or browser settings and some websites or browsers may have different features regarding your ability to choose which ads to display or opt out from receiving. Please refer to the applicable website that you are visiting for additional information.

do not track signals

Some web browsers may have a “do not track” option that allows you to opt out of having your on-line activities tracked. As a uniform technological standard has not yet been developed regarding this technology, the Seller Owned Websites are not currently set up to respond to this feature, and, therefore, we do not take action to respond to such “do not track” signals.

our commitment to information security

Information security is important to Seller, and while no security measure is perfect or impenetrable and we cannot guarantee the security of the information that you provide to us, you can be assured that we maintain physical, electronic and administrative measures and safeguards and periodically review these security measures and safeguards to protect your Personally Identifiable Information from unauthorized or inappropriate access and use.

our commitment to children’s privacy

To reiterate, our Communication Points are not directed at minors, and we do not knowingly solicit or collect personal information from or about children, particularly those  under the age of thirteen (13). Should any parent or guardian discover that his/her child has provided personal information to Seller, please contact Seller at info@sureguard.ca to have such information deleted from our records.

how to access or update your information

You can access, edit, delete and update any Personally Identifiable Information that you provided to us by visiting your profile page on the applicable Seller website (if you are a registered user) or by contacting us at info@sureguard.ca We use this procedure to better safeguard your Personally Identifiable Information. To protect your privacy and security, we will also take steps to verify your identity before granting you access to edit or update your Personally Identifiable Information.

Your Privacy Preferences Regarding Personally Identifiable Information – Opting In/Out

You can opt out of receiving promotional communications from Seller by notifying us that you do not wish to receive such information by contacting us a Seller’s email preferences (if you are a registered user), by contacting us at info@sureguard.ca or by contacting us, in writing, at: 37525 Interchange Dr., Farmington Hills, MI 48335 Attention: E Commerce Director. Please note that if you have opted out of receiving promotional communications from us, Seller may still send you non-promotional communications (such as, for example, information about your accounts or purchases). In addition, in the event you have opted out but in the future desire to receive promotional information from Seller, you may opt in by contacting us at info@sureguard.ca.

Chances To Privacy Policy

By visiting any of the Communication Points, or otherwise providing Seller with your information, you are subject to the terms of this Privacy Policy and consent to our collection and use of your information as set forth in this Privacy Policy. Seller reserves the right to update, modify, or supplement this Privacy Policy, including our collection and use and related business practices, at any time by posting updated text on our Seller-Owned Websites, however we will not materially reduce your rights under this Privacy Policy with respect to previously provided information, without your consent. Changes to this Privacy Policy are effective at the time they are posted to our Seller Owned Websites. For this reason, it is your responsibility and Seller encourages you to review this Privacy Policy each time you visit any of our Seller-Owned Websites.

How To Contact Us

If you have any questions, comments or concerns with respect to our privacy practices or this Privacy Policy statement, please feel free to contact us at Encore Commercial Products, Inc., Attn: E-Commerce Director, 37525 Interchange Dr., Farmington Hills, MI 48335. Email address: info@sureguard.ca