Privacy Policy

Last Updated: March 2023

1. Introduction

Glenroy, Inc. (together with its subsidiaries, divisions, and brands, collectively, the “Company,” “us,” “we,” or “our,” as the context may require) operates and provides the website glenroy.com. This Privacy Policy (this “Policy“) describes our privacy practices for that website (the “Site“), including the types of information we may collect from you when you visit the Site and our practices for collecting, using, protecting, and disclosing that information. We respect the privacy of the users of the Site (“you” or “your,” as the context may require) and we are committed to respecting your privacy and the security of your personal information through compliance with this Policy.

Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. By accessing or using the Site, you agree to this Policy and our Terms of Use.[1] If you do not agree with our policies and practices, please do not visit, access, use, or otherwise interact with the Site.

This Policy may change from time to time (see Section 11 (Changes to this Policy)). Your continued use of the Site after we revise this Policy means you accept such revisions and agree to abide and be bound by the most recent version of the Policy, so please check this Policy periodically for updates.

2. The Interactions this Policy Covers

This Policy describes and applies exclusively to personal information (as defined below) that we collect on or in connection with the Site and in texts, emails, and other electronic communications sent through or in connection with the Site. Except as otherwise provided in this Policy or as required by applicable law, this Policy does not apply to information that is collected by any application, website, or third party other than the Site, including through any application or content that may access, be linked to, or otherwise be accessible from the Site. If you visit an application, website, or third party that we mention or link to, be sure to review its privacy policy before providing it with any information, as that privacy policy will apply to your interactions with that application, website, or third party.

Except as otherwise provided in this Policy, “personal information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you. “Personal information” does not include information which is generally not considered “personal information” under applicable law or is otherwise exempted under applicable law, such as information which is publicly available or subject to special data privacy laws and/or regulations.

Terms & Conditions

3. Information We Collect

We collect several types of information from and about you as a result of your use of or registration with the Site and as a result of your communication with us. This information may include:

Personal information, such as:
- Identifiers, including your name, username, physical address, email address, phone number, and other similar identifiers.
- Commercial information, including your payment information, product preference information, and other information related to your purchases or potential purchases.
- Professional or employment information, including education and work history, when you apply to work with us.
- Inferences drawn from any of the above.
- Any other personal information that you upload or share to or on the Site, or which you otherwise provide directly to us.
Information that is about you but individually does not identify you, such as information which has been de-identified or aggregated in a manner where it can no longer be used to identify you.
Information about your internet connection and the equipment you use to access the Site; IP address, approximate location, and other unique device identifiers; your activity on the Site; and other usage details collected through your use of the Site.
Any other information, including personal information, which you publicly disclose or share.

4. How We Collect Personal Information

We may collect personal information:

· Directly from you when you provide it to us;

· Automatically when you use or access the Site; and

· From third parties, such as our service providers.

A. Information We Collect Directly

The personal information we collect directly from you when you use or access the Site includes:

Information that you provide by filling in forms or making purchases on the Site. This includes information provided at the time of requesting further information or reporting a problem with the Site.
User profile information provided at the time of registering to use the Site and throughout the period you are logged into the Site.
Your voluntary responses to surveys that we might ask you to complete.
Details of transactions you carry out through the Site and of the fulfillment of your orders.
Your search queries on the Site.
Records and copies of your communications when you contact us.

B. Information We Collect Automatically

As you navigate through and interact with the Site, we may use automatic data collection technologies to collect certain information, including:

Usage details. When you access and use the Site, we may automatically collect certain details of your access to and use of the Site, including traffic data, approximate location data, logs, and other communication data and the resources that you access and use on or through the Site.
Device information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
Stored information and files. The Site also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

The information we collect automatically is only statistical data and does not generally include personal information, but we may maintain it or may associate it with other personal or business information we collect in other ways or receive from third parties. This information helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Site according to your individual interests.
Speed up your searches.
Recognize you when you return to the Site.

The technologies we use for automatic information collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. We use both session-based and persistent cookies. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Site, and overall functionality of the Site may be impaired. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
We may utilize third party companies and analytics to help us market, sell, and provide information about our products and services. We may use web analytics tools provided by service providers, including, but not limited to, Google Analytics, which is a third-party service that transmits website traffic data to Google services in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We may use reports provided by Google Analytics and similar service providers to help us understand traffic on the Site. For more information, concerning Google Analytics and how it collects and processes data, please see “How Google Uses Data When You Use Our Partners Web Sites or Apps,” located at www.google.com/policies/privacy/partners. We may use the information provided by these tools to improve our services and our online advertisements. These tools place session and persistent cookies in your browser to identify you as a unique user the next time you visit, access, or use the Site. Each cookie cannot be used by anyone other than the service provider (e.g., Google Analytics).

C. From Third Parties

We may also receive personal information or draw inferences about you from other sources, including service providers who collect or process information on our behalf. We generally require these service providers to use your personal information only as we direct and in a manner consistent with this Policy.

We may offer the opportunity to engage with our website and content we produce on or through third-party social networking websites, plug-ins, and applications. When you engage with our content on or through third-party social networking websites, plug-ins, and applications, you may allow us to have access to certain information associated with your social media account, which may include personal data (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in, or application. When you provide information from your social media account, we may, through third party advertisers or the social media host website or application, use this information to personalize your experience on the third-party social networking websites, plug-ins, and applications, and to provide you with other products or services you may request. We do not build profiles based on this information. The sharing of such information is exclusively controlled by the social media platform you are using. If you do not wish to share such information or exercise any data subject rights related to such information, please refer to the privacy notices or policies of the social media platform you are using.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Section 8 (Other Privacy Choices) below.

5. How We Use Your Personal Information

We may use the personal information that we collect about you or that you provide to us:

To provide you with the Site, all related content, and any other information, products, or services that you request from us.
To create, manage, maintain, and secure your account and to provide you with notices about your account.
To communicate with you and to process your requests, purchases, and payments.
To give you notices about your account.
To deliver our newsletter to you.
To notify you of changes to any products or services we offer or provide though the Site.
To notify you to participate in interactive features of the Site.
To help you identify dealer locations.
To help maintain the safety, security, and integrity of the Site, as well as our products, services, databases, and other technology assets.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
For testing, research, analysis, and product development, including to understand our audience, develop and improve the Site, as well as our customer service, products, and services.
To respond to law enforcement requests and, as required by applicable law, court order or governmental regulations.
To evaluate, negotiate, or conduct a merger, divestiture, restructuring, reorganization, dissolution, other sale or transfer of some or all of our assets, or the negotiation thereof, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users and customers is among the assets transferred.
To fulfill any other purpose for which you provide it.
For any other purpose with your consent.

6. Disclosure of Your Information

We may disclose personal information that we collect or you provide from any category identified above in Section 3 (Information We Collect):

To our subsidiaries and affiliates.
To contractors, service providers, advisors, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose it to them.
To an actual or perspective buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
To fulfill the purpose for which you provide it.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce our rights arising from any contracts entered into between you and us, and for billing and collection.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may use or disclose aggregated information about our users and information that does not identify any individual without restriction.

7. Your Privacy Rights

We provide all users with rights to:

Confirm whether we process their personal information.
Access, correct, and delete certain personal information.
Data portability.
Opt-out of personal data processing for targeted advertising and sales.
Opt-out of certain types of profiling.

To exercise any of these rights, please contact us using the information set forth in Section 12 (How to Contact Us) below. We may deny a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect, and we may retain copies of your personal information to the extent required by applicable law.

To appeal a decision regarding a consumer rights request, please contact us as set forth in Section 12 (How to Contact Us).

8. Other Privacy Choices

We strive to provide you with as many choices as possible regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Account Access. You can review, change, and remove some of your personal information by logging onto the Site and visiting your account profile page.
Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Site may then be inaccessible or not function properly.
Promotional Offers from Us. If you do not wish to have your contact information used by the us to promote our own products or services, you can opt-out by unsubscribing from any emails you received from us or a third party. You can also always opt-out by contacting us as provided in Section 12 (How to Contact Us).
Accessing and Updating Your Information. To update your information (name, mailing address, telephone number, and email address), you can review and change some of your personal information by logging into the Site and visiting your account settings page. You may also contact us as provided in Section 12 (How to Contact Us) to update your information.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website, https://thenai.org/opt-out. Similarly, you can opt out of receiving targeted ads from members of the Digital Advertising Alliance (“DAA“) on the DAA’s website, https://www.privacyrights.info.

If you are a resident of certain jurisdictions (e.g., European Economic Area, California), you may have additional rights and choices regarding your personal information. Please see Section 13 (Notice for Individuals Located in the European Economic Area) and Section 14 (Notice for California Residents) for additional information.

9. Security

We implement various physical, administrative, and technical safeguards in accordance with industry standards to protect the security of your personal information both online and offline. The safety and security of your information also depends on you. Where you have a password for access to certain parts of the Site, you are responsible for keeping this password confidential. Do not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site. 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 Site.

10. Children’s Privacy

The Site is not directed to nor intended for use by children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are under age 16 years of age, do not use or provide any personal information to, on, or through the Site. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us using the information set forth in Section 12 (How to Contact Us).

11. Changes to this Policy

We reserve the right to review and revise this Policy from time to time, without prior notice, subject to applicable legal requirements to notify you or obtain your consent. The date this Policy was last reviewed and/or revised is noted at the top of the page. You are responsible for periodically visiting the Site and this Policy to check for any changes. Your continued use of the Site following the posting of changes constitutes your acceptance of such changes.

12. How to Contact Us

To ask questions or comment about this Policy and our privacy practices, you may contact us:

Via mail at W158 N9332 Nor-X-Way Avenue, Menomonee Falls, WI 53051.
Via phone at 1-800-824-1482.
Via email at info@glenroy.com.

If you are a Data Subject and feel we have not resolved a privacy concern related to personal information processed or transferred by the Company, you have the right to submit a complaint to a supervisory authority.

13. Notice for Individuals Located in the European Economic Area

A. Scope

This Section 13 applies exclusively to visitors and users of the Site who are located in the European Union (EU) and/or European Economic Area (EEA) (“Data Subjects“).

B. Rights of Data Subjects

We want to make sure you are fully aware of all of your data protection rights. If you are a Data Subject, you have the following rights:

You have the right to request copies of your personal information. If you require more than one copy, we may charge you a reasonable fee.
You have the right to request that we correct any personal information that you believe is inaccurate, or to complete any personal information which you believe is incomplete.
You have the right to request that we erase your personal information, under certain circumstances.
Restrict Processing. You have the right to request that we restrict the processing of your personal information, under certain circumstances.
Object to Processing. You have the right to object to our processing of your personal information, under certain circumstances.
Data Portability. You have the right to request we transfer data that we have collected to you or directly to another organization, under certain circumstances.
Withdraw Consent. You have the right to withdraw your consent, explicit or otherwise, at any time. If we rely on your consent as the legal basis for our processing of your personal information, we will refrain from processing your data.

For the purposes of European data protection laws, we are the data controller, i.e., the company responsible for controlling the processing of personal information covered by this Policy.

If you are a Data Subject and would like to exercise any of these rights, please contact us as provided in Section 12 (How to Contact Us).

C. Transfer of Personal Information

The Site is operated and managed on servers located and operated in the United States. Any information collected through the Site as described in this Policy is stored in the United States. The United States is not recognized as having adequate safeguards by the European Economic Area. If you are located outside of the United States, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer, storage, and further processing of information to the United States.

14. Notice for California Residents

A. Scope; Definitions

This Section 14 (Notice for California Residents) applies exclusively to visitors and users of the Site who reside in the state of California (“Consumers“). We provide our Notice for California Residents to supplement our main Privacy Policy and to comply with California privacy laws, including the California Consumer Privacy Act of 2018 (the “CCPA“). Notwithstanding anything to the contrary elsewhere in this Policy, terms defined in the CCPA have the meaning assigned to them under the CCPA when used in this Notice for California Residents.

If you are a Consumer, the CCPA provides you with certain rights regarding your personal information. This Section 14 includes additional notices with respect to and describes those rights and provides you with additional information regarding our practices regarding the collection, use, disclosure, and sale of personal information.

B. Personal Information We Collect

We may collect, and in the last twelve (12) months have collected, the following categories of personal information from Consumers:

[1] [NTD: Please insert hyperlink to Terms of Use before removing this footnote.]

Category	Examples
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
C. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
D. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
E. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

A. Sources of Personal Information

We may collect your personal information from the categories of sources of personal information identified in Section 4 (How We Collect Personal Information).

B. Use of Personal Information

We may use, disclose, or otherwise process the personal information we collect for the purposes identified in Section 5 (How We Use Your Personal Information) and Section 6 (Disclosure of Your Information).

C. Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information.

Personal Information Category	Category of Third-Party Recipients
Personal Information Category	Business Purpose Disclosures	Sales
A. Identifiers	Service providers (e.g., marketing vendor, shipping vendor, payment processor, etc.)	None
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Service providers (e.g., marketing vendor, shipping vendor, payment processor, etc.)	None
C. Commercial information	Payment processor	None
D. Internet or other similar network activity	Internet and cloud service providers, operating systems and platforms, data analytics providers	None
E. Inferences drawn from other personal information	None	None

A. Your Rights and Choices

The CCPA provides Consumers with certain rights regarding their personal information. This Section 14(F) describes these rights and explains how you may exercise them.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months (your “Right to Know“). Once we receive your request and confirm your identity, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

The specific pieces of personal information we collected about you (also called a “Data Portability Request“).

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (your “Right to Delete“). Once we receive your request and confirm your identity (see Section 14(iii) (Exercising Your Rights to Know or Delete)), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your Right to Know or your Right to Delete described above, please submit a request by either:

Calling us at 1-800-824-1482; or
Emailing us at info@glenroy.com.

Only you or your authorized agent may make a verifiable consumer request related to your personal information. To designate an authorized agent, contact us through one of the methods listed above.

You may only make a Request to Know, Data Access Request, or Data Portability Request twice within a twelve (12) month period. Your Request to Know, Data Access Request, or Data Portability Request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or are an authorized representative of such person, which may include:
- Information which we already maintain; or
- If we cannot verify your identity based on information already maintained by us, such information that we or our representatives request from you.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within this timeframe, please contact us as provided above.

We try to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period. We cannot respond to your request or provide you with personal information unless we can verify your identity or authority to make the request and confirm the personal information relates to you. If we cannot verify your request within forty-five (45) days of its receipt, we may deny your request.

Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Personal Information Sales Opt-out and Opt-in Rights

If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell personal information and therefore do not sell the personal information of Consumers we actually know are less than 16 years old.

Non-Discrimination; Notice of Financial Incentives

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

1. Notice for Nevada Residents

This Section 15 applies exclusively to visitors and users of the Site who reside in the state of Nevada. Nevada provides its residents with a limited right to opt-out of certain personal information sales. Nevada residents who wish to exercise this sale opt-out right may email us at info@glenroy.com. Please include “Nevada” in your email subject line and include the following information in your email: (i) your name, (ii) Nevada resident address, and (iii) email address. However, please know we do not currently sell data triggering that statute’s opt-out requirements.