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PRIVACY POLICY

 

This website (the “Site”) is operated by Fulfilling Inc. If you visit our Site, use our services, or contact us, this policy is for you. It explains how we protect your personal information and respect your privacy.

By accessing or using this Site, you agree to this Privacy Policy. If you do not agree, please refrain from using our Site.

We last updated this Privacy Policy in December 2024.

WHO WE ARE & HOW TO REACH US?

Fulfilling Inc., a Delaware corporation with its registered address at 1007 N Orange St. 4th Floor STE 1382, Wilmington, DE, 19801.

Any reference to ‘us’, ‘we’, ‘our’ or the Company within this Privacy Policy includes all or any of the direct or indirect parent or subsidiary undertakings.

CHANGES TO THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time to reflect:

  • Changes in applicable laws or regulatory requirements.

  • Updates to our data practices or the features and functionality of our Site.

  • Advancements in technology or other relevant changes.

Staying Informed

We encourage you to review this page periodically to stay informed about how we protect your Personal Information. The "last updated" date at the top of this Privacy Policy indicates when the most recent changes were made.

Notification of Significant Changes

If we make material changes to this Privacy Policy that affect your rights or require your consent, we will notify you in advance through appropriate channels, such as:

  • Posting a prominent notice on our Site.

  • Sending an email to the contact information you have provided, if applicable.

Your continued use of our Site following the effective date of the updated Privacy Policy constitutes your acknowledgment and acceptance of the changes.

PERSONAL INFORMATION

“Personal Information” is any information that identifies, relates to, or can reasonably be associated with you as an individual. Fulfilling Inc. determines how this information is collected, used, and shared in compliance with applicable U.S. laws, including the California Consumer Privacy Act (CCPA) and other state-level privacy laws.

YOUR INFORMATION COLLECTED BY US

As you engage with our Site, we gather Personal Information through the following means:

  • Personal Information automatically collected by us: when you access our Site, we automatically procure certain details regarding your engagement and activities within the Site. This may entail specifics about your device, such as its model, operating system, IP address, and information related to your actions within the Site.

  • Personal Information acquired via cookies: to understand your interactions with our Site better, we utilize cookies and similar technologies. Cookies enable us to retain particular details about you, such as your preferences or previous interactions, thereby enhancing your experience on our Site and delivering tailored content.

  • Personal Information you provide directly: to enhance your experience and fulfill your requests, we collect Personal Information that you voluntarily share with us. This includes details such as your name, email address, and phone number when submitting forms, inquiries, or feedback. Additionally, we may gather information from your interactions with our customer support team, as well as responses to surveys, promotions, or contest entries you participate in.

Please note that this Privacy Policy does not apply to information collected by:

  • us offline or through any other means, including on any other website or applications operated or distributed by us or any third party;

  • any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Site.

WHAT INFORMATION WE COLLECT?

We collect the following categories of Personal Information from you. This includes, but is not limited to:

  • Identifiers: Such as your name, email address, phone number, or other contact information provided when you contact us or leave questions, queries, or feedback.

  • Device and Browser Information: Including your Internet Protocol (IP) address, browser type and version, operating system, and device details.

  • Usage Data: Information about your interactions with the Site, such as pages viewed, links clicked, time spent on the Site, and referral sources.

  • Cookies and Tracking Information: Details collected through cookies or similar technologies, including browsing behavior, preferences, and interactions.

Additional Categories for California Residents

Under the California Consumer Privacy Act (CCPA), the types of Personal Information we collect may fall into the following categories:

  • Personal Identifiers: Name, email address, and IP address.

  • Internet or Network Activity: Information about how you use the Site and interact with online content.

  • Geolocation Data: If enabled, approximate location derived from your IP address.

  • Inferences: Preferences or characteristics inferred from your interactions with our Site.

HOW WE USE YOUR INFORMATION?

We use the Personal Information we collect for the following purposes:

  • Service and Product Information: To provide you with information about our services, products, and updates that you request.

  • Site Functionality: To enhance the performance and functionality of the Site, respond to your inquiries, and fulfill your requests.

  • User Experience and Security: To understand how you use the Site, improve user experience, and ensure the Site remains secure.

  • Compliance: To comply with legal obligations, enforce our terms, and protect the rights, property, or safety of our users and business.

  • Legitimate Business Interests: To support our business operations, such as maintaining Site functionality, enhancing product offerings, and conducting analytics.

HOW LONG WE KEEP YOUR INFORMATION

We retain your Personal Information only for as long as is necessary to fulfill the purposes outlined in this Privacy Policy, or as required by applicable laws, contractual obligations, or regulatory requirements. Specifically:

  • Retention Periods: The duration depends on the nature of the information and the reason for its collection.

  • Deletion or Anonymization: Once the applicable retention period expires, we will securely delete or anonymize your Personal Information in compliance with applicable laws. If deletion or anonymization is not possible (e.g., stored in backup systems), we will securely store your Personal Information and restrict further processing until deletion is feasible.

DO ANY THIRD PARTIES PROCESS YOUR INFORMATION?

We may share your Personal Information with trusted third parties to provide you with access to our Site, improve your experience, and fulfill the purposes described in this Privacy Policy. These include:

  • Service Providers: Employees, agents, and external vendors who perform services on our behalf, such as website hosting, analytics, customer support.

  • Legal and Regulatory Compliance: When required, we may disclose your information to comply with legal obligations, enforce our terms and policies, or protect our users and business (e.g. responding to lawful requests from authorities; or facilitating corporate transactions, such as mergers or acquisitions).

Aggregated or De-Identified Data: We may allow service providers to use aggregated or de-identified information for lawful business purposes, provided it does not identify you

We will not:

  • sell or rent your Personal Information to third parties; or

  • share your Personal Information with third parties for marketing purposes.

WHAT ABOUT LINKED THIRD-PARTY SERVICES?

Our Site may contain links to third-party websites, resources, vendors, advertisers, and other products and services. Please note the following:

  • No Control Over Third Parties: We do not control and are not responsible for the privacy practices, content, products, or services provided by these third parties.

  • Independent Data Collection: These third parties may collect and process your Personal Information independently. This information is not governed by this Privacy Policy.

  • Their Policies Apply: These third parties have their own privacy policies and terms of use, which may include details about: how they collect, use, and share your Personal Information; your privacy rights and choices, including opt-out options; whether they process and store data in the United States or other countries.

We strongly encourage you to review the privacy policies, practices, and terms of any third-party service before engaging with them or providing your Personal Information. If you have concerns about how a third party handles your Personal Information, contact them directly for clarification.

WHERE YOUR INFORMATION IS PROCESSED AND STORED?

We primarily store and process your Personal Information within the United States, using secure servers and systems to protect your Personal Information. However, in some cases, your Personal Information may be transferred to and processed by third-party service providers located outside the United States.

To safeguard your privacy in such instances:

  • Protective Measures: We implement contractual agreements and other safeguards to ensure your Personal Information is handled securely and in compliance with applicable U.S. data protection laws.

  • Security and Confidentiality: These measures are designed to protect the confidentiality and integrity of your Personal Information, regardless of its processing location.

YOUR STATUTORY RIGHTS REGARDING PERSONAL INFORMATION

Depending on your location, you may have specific statutory rights concerning your Personal Information under applicable U.S. privacy laws. These rights may include the ability to:

  • Access Information: Request the categories of Personal Information we have collected about you, the sources from which it was collected, and the commercial purposes for collecting it.

  • Disclosure of Sharing: Request the categories of third parties with whom we have shared your Personal Information and the specific categories of information disclosed.

  • Review Collected Information: Request a copy of the specific pieces of Personal Information we have collected about you.

  • Request Deletion: Request that we delete Personal Information we have collected about you, subject to certain exceptions provided by law.

  • Correct Inaccuracies: Request correction of any inaccurate Personal Information we hold about you.

  • Opt-Out of Sale or Sharing: Request that we do not sell or share your Personal Information ata with third parties for monetary or other valuable consideration.

HOW CAN YOU ACCESS, CORRECT, OR UPDATE YOUR PERSONAL INFORMATION?

You have the right to request access to the Personal Information we hold about you, as well as the ability to request updates or corrections to ensure its accuracy and completeness. To make such a request:

  • How to Submit a Request: You can email us at info@fulfilling-us.com with details of your request. Please include sufficient information to help us verify your identity and process your request efficiently. Even if you request that we update, correct, or delete your Personal Information, we may be required or permitted to retain certain information in compliance with applicable laws.

HOW WE RESPOND TO DO NOT TRACK SIGNALS?

The "Do Not Track" (DNT) feature is a privacy preference that some web browsers offer, allowing users to indicate their preference not to be tracked by websites or online services. However, at this time, there is no universally accepted standard for implementing DNT signals, and not all browsers support this feature. Consequently, we do not currently respond to DNT signals.

SECURITY

We take the security of your Personal Information seriously and implement industry-standard measures to protect it. These include:

Encryption: All interactions on our Site are secured using SSL encryption (HTTPS).

Secure Storage: Our databases are encrypted and stored on servers with robust security protocols.

While we are committed to safeguarding your Personal Information, no method of transmission or storage is completely secure. As such:

  • we cannot guarantee absolute security or that your Personal Information will never be accessed, used, or disclosed in a manner inconsistent with this Privacy Policy.

  • potential risks include unauthorized access, hardware or software failures, and other unforeseen factors.

Breach Notification

In the unlikely event of a data breach involving the unauthorized or unlawful access, use, or disclosure of your Personal Information:

  • we will notify you promptly in accordance with applicable laws.

  • notifications may be sent electronically, in writing, by telephone, or through other appropriate means, depending on the circumstances.

Reporting a Security Concern

If you suspect a data breach or have concerns about the security of your Personal Information, please contact us immediately at: info@fulfilling-us.com

CHILDREN’S PRIVACY PROTECTION

Our Site is not intended for, nor directed at, children under 13 years of age. We do not knowingly collect, use, or maintain Personal Information from individuals under the age of 13.

If we become aware that we have inadvertently collected Personal Information from a child under 13, we will promptly delete such information from our records in compliance with the Children's Online Privacy Protection Act (COPPA).

If you believe that a child under 13 has provided us with Personal Information, please contact us immediately at: info@fulfilling-us.com.

ADDITIONAL RIGHTS AND CHOICES OF U.S. RESIDENTS

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS, US

No Sale of Personal Information

We do not sell your Personal Information for monetary gain, nor are we in the business of trading Personal Information. However, like many online businesses, we collaborate with third parties to manage advertisements on various platforms and websites. In some cases, we may share basic Personal Information with these partners to provide targeted ads. Under the California Consumer Privacy Act (CCPA), this sharing may be considered "selling" or "sharing" Personal Information.

If you wish to opt out of such Personal Information sharing, please refer to the Opt-Out Provision below.

Opt-Out Provision

Even though we don't make money by selling your personal info, you still have the right to opt out of sharing it with our analytics and advertising partners, as defined by California or other relevant US state laws. You can do this by adjusting your browser settings by reaching out to us directly at info@fulfilling-us.com.

Limitation on Handling Sensitive Information.

We only process sensitive Personal Information when absolutely necessary to provide you with products or access to use Site.

Request for Access.

You have the right to request access to:

  • The Personal Information We Have About You: This includes sensitive Personal Information and how it is used or processed.

  • Categories, Sources, and Recipients: Details of the categories of Personal Information we collect, the sources from which we collect it, and any third parties with whom it has been shared, sold, or disclosed in the past 12 months.

You can submit an access request up to twice per year at no cost. You can do this by reaching out to us directly at info@fulfilling-us.com.

California Residents' Rights.

Residents of California have the right to request, once a year, disclosure regarding any Personal Information shared with third parties for their separate direct marketing purposes. Even though we do not share information with third parties for marketing, you can reach out to us. Please ensure the subject line reads "California Privacy Rights Request," and include relevant details such as your name, street address, city, state, and ZIP code.

Right to Delete Personal Information

You have the right to request that we delete the Personal Information we have collected about you. To make such a request, contact us at info@fulfilling-us.com. Please note, certain information may be retained where necessary for legal, security, or business continuity purposes, as permitted under applicable laws.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights under the CCPA. This includes:

  • Denying you services.

  • Charging different prices or rates for services.

  • Providing a different level or quality of services.

If you believe you have been subject to discrimination, please contact us immediately at info@fulfilling-us.com.

All mentions of "Personal Information" in this policy include "sensitive/personal information" as defined by California laws.

PRIVACY NOTICE FOR VIRGINIA, CONNECTICUT, COLORADO, UTAH, AND NEVADA, US

We include this section for residents of other US states with privacy laws that may impact them. These privacy laws include the Virginia Consumer Data Privacy Act (“VCDPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), the Colorado Privacy Act (“CPA”), and the Nevada Privacy Law (“NPL”), the Montana Consumer Data Privacy Act (“MCDPA”), the Oregon Consumer Privacy Act (“OCPA”), and the Texas Data Privacy and Security Act (“TDPSA”). This section is intended to comply with these laws by supplementing the information provided elsewhere in the Privacy Policy.

Collection of Personal Information

We may collect Personal Information as described and categorized elsewhere in this Privacy Policy. The specific definitions of sensitive information vary by state law.

Use of Personal Information

We may collect, use, and disclose Personal Information for the purposes outlined in this Privacy Policy. This includes providing services, improving our products, and complying with legal obligations.

Disclosure of Personal Information

We may disclose Personal Information to third parties and service providers as described in this Privacy Policy. We ensure such disclosures comply with applicable laws to protect your privacy and rights.

General Privacy Rights

Residents of Colorado, Connecticut, Virginia, Utah, Montana, Oregon, and Texas are entitled to the following rights concerning their Personal Information:

  • Access: You have the right to request and receive a copy of the Personal Information we have collected about you.

  • Correction: You can request corrections to inaccurate or outdated Personal Information.

  • Deletion: You have the right to request the deletion of your Personal Information, subject to specific exceptions under the law.

  • Data Portability: You can request that Personal Information be provided in a portable, easy-to-read format to enable its transfer to another service provider.

Opt-Out Rights:

  • Targeted Advertising: You can opt out of your Personal Information being used for targeted advertising.

  • Sale of Personal Information: You can opt out of the sale of your Personal Information to third parties. Note: We do not sell Personal Information for monetary consideration.

  • Profiling: You can opt out of automated decision-making processes that profile you for significant decisions, such as those affecting your legal, financial, or employment status.

State-Specific Rights

Each state has unique provisions under its privacy laws. Below are additional details for residents of Montana, Oregon, Texas, and Nevada.

Montana

  • Profiling Opt-Out: You may opt out of the use of your Personal Information for profiling purposes.

  • Data Sales Opt-Out: You can opt out of the sale of Personal Information.

  • Current Practices: We do not engage in profiling or sell Personal Information for monetary consideration.

Oregon

  • Access, Correction, and Deletion Rights: You can request access to your Personal Information, correct inaccuracies, or request its deletion.

  • Data Sales and Targeted Advertising Opt-Out: You have the right to opt out of the sale of your Personal Information and the use of your information for targeted advertising.

  • Compliance: We fully comply with the requirements of the Oregon Consumer Privacy Act (OCPA) to safeguard your rights and Personal Information.

Texas

  • Transparency: You have the right to know the types of Personal Information we collect, process, and store about you.

  • Data Correction and Deletion: You may request corrections to inaccuracies or deletion of your Personal Information.

  • Opt-Out Rights: You can opt out of targeted advertising and profiling practices.

Nevada

  • Sale of Information: Nevada residents have a limited right to opt out of the sale of Personal Information. Note: We do not sell Personal Information for monetary consideration.

How to Exercise Your Rights

To exercise any of the rights outlined above:

  • Submit a Request: Contact us using the methods specified in our Privacy Policy. Include your full name, state of residence, and details of the request to help us process it efficiently.

  • Verification Process: We may require you to verify your identity to protect your Personal Information and comply with legal obligations.

  • Response Timeline: We will respond to verifiable requests within the timeframe specified by applicable state laws (typically 30 to 45 days).

Use of the Services by International Users

In circumstances where users outside the U.S., such as those in the EU, EEA, UK, or Switzerland, access our Site, we recognize certain data protection obligations. For users in these regions, under applicable law, we may be deemed a “data controller,” meaning we determine the purposes and means of processing your Personal Information. If applicable, your privacy rights are detailed below.

YOUR PRIVACY RIGHTS IN THE EU, EEA, UK, AND SWITZERLAND

If you are a resident of these regions, you have the following rights under applicable privacy laws:

  • Access: Request a copy of your Personal Information.

  • Rectification: Ask us to correct incorrect or incomplete Personal Information.

  • Objection: Object to how we use your Personal Information.

  • Erasure: Request deletion of your Personal Information.

  • Restriction: Ask us to limit how we use your Personal Information.

  • Portability: Request your Personal Information in a machine-readable format and transfer it to another entity.

  • Withdrawal of Consent: Withdraw your consent for Personal Information use at any time.

  • File Complaint: Lodge a complaint with your country’s supervisory authority.

Data Transfers and Safeguards

As a U.S.-based organization, we process Personal Information within the United States. If we transfer Personal Information from the EU, EEA, UK, or Switzerland to the U.S. or another jurisdiction, we implement robust safeguards, including:

  • Adequacy Decisions: Transferring data only to countries approved by the European Commission for maintaining an adequate level of data protection.

  • Standard Contractual Clauses (SCCs): Employing contractual obligations to ensure the protection of your personal data during and after transfer.

  • Additional Measures: Supplementing SCCs with technical and organizational measures to enhance data security.

Exercising Your Rights

To exercise your privacy rights:

  • Contact us at info@fulfilling-us.com. Include your name, country of residence, and the nature of your request.

  • We may request additional information to confirm your identity and residency.

  • We will respond to verifiable requests within the timeframes established by applicable laws, typically within 30 days.

If you believe your rights have been violated, you may lodge a complaint with your local data protection authority. However, we encourage you to contact us first to resolve your concerns directly.

Marketing and Advertising Choices

Residents of the EU, EEA, UK, and Switzerland may withdraw consent for receiving marketing communications at any time by contacting us at info@fulfilling-us.com. You may also manage cookies and other tracking preferences through your browser settings or refer to us for more information.

Legal Basis for Data Processing

Under GDPR and similar laws, we process your Personal Information based on:

  • Consent: You have provided explicit consent for processing.

  • Contractual Necessity: The data is required to fulfill our contractual obligations to you.

  • Legal Obligations: Compliance with our legal responsibilities.

  • Legitimate Interests: Activities reasonably expected, such as fraud prevention, service improvement, and secure operation of our platforms.

COOKIES

Cookies are a standard feature of websites that allow us to store small amounts of Personal Information on your computer about your visit to our Site. Cookies help us learn which areas of the Site are useful and which areas need improvement. Please be aware that if cookies are disabled, your experience on the Site may be diminished, and not all features of the Site may operate as intended.

We use cookies and similar technologies that are strictly necessary for the Site to function properly. These cookies help us provide essential functionality and ensure the Site operates as expected. For example, certain information is automatically collected by most browsers or through your device, including:

  • Media Access Control (MAC) address.

  • Computer type (e.g., Windows or Mac) and operating system name and version.

  • Screen resolution and device manufacturer/model.

  • Language, Internet browser type and version.

  • The name and version of the Site you are using.

We use this information to optimize the performance of the Site and ensure compatibility with your device.

Third-Party Tracking Technologies

We do not control third parties' tracking technologies or how they may be used on our Site. If you have questions about advertisements or other targeted content displayed to you, we recommend contacting the relevant third-party provider directly.

Opting Out of Targeted Advertising

To learn how to opt out of targeted advertising, you can visit the Network Advertising Initiative’s (NAI)

Network Advertising Initiative's ("NAI") education and opt out pages; and NAI Consumer Opt-out

You can opt out of targeted advertising by:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance's opt-out portal at: WebChoices tool.

HOW TO CONTACT US

We hope all of the above makes sense, and you’re happy with how we use your Personal Information. If not, please contact us at info@fulfilling-us.com or via post to at 1007 N Orange St. 4th Floor STE 1382, Wilmington, DE, 19801. Please mark the envelope ‘Personal Information Inquiry.

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