PRIVACY POLICY

This website (“Website”) is provided by PrimeSource Building Products, Inc. (“Company”).
PLEASE READ THESE TERMS AND CONDITIONS AND PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE. YOUR USE OF THIS WEBSITE CONFIRMS YOUR UNCONDITIONAL ACCEPTANCE OF AND AGREEMENT TO THE TERMS CONTAINED HEREIN. THE COMPANY RESERVES THE RIGHT TO PERIODICALLY UPDATE AND MODIFY THESE TERMS AND CONDITIONS AND THE PRIVACY POLICY WITHOUT FURTHER NOTICE TO YOU. IF YOU DO NOT ACCEPT THESE TERMS AND CONDITIONS, PLEASE DO NOT USE THIS WEBSITE.

Introduction

PrimeSource Building Products, Inc. (“Company”, “we” or “us”) respects your privacy and is committed to protecting it through our compliance with this privacy policy (the “Policy”).

This Policy describes the types of information we may collect from you or that you may provide when you visit the website www.primesourcebp.com, www.grip-rite.com or www.pro-twist.com or the platforms detailed below (collectively the “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Website. By accessing or using the Website, you agree to this Policy. This Policy may change from time to time. Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

For your convenience, the Website may contain links to a number of other websites. The privacy policies and procedures described here do not apply to those sites; we suggest contacting those sites directly for information on their data collection and distribution policies. Any reference to a linked site or any specific third-party product or service by name does not constitute or imply its endorsement by us, and you assume all risk with respect to its use.

This Policy applies to information we collect from the following platforms:

The www.primesourcebp.com, www.grip-rite.com or www.pro-twist.com websites.
In email, text, and other electronic messages between you and the Website.
In email, text, and other electronic messages between you and the Company.
Through mobile and desktop applications you download from the Website, or from application stores such as the Google Play Store or Apple App Store, which provide dedicated non- browser-based interaction between you and the Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.
It does not apply to information collected by:

Use offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Children Under the Age of 16
The Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features, or register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. 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 at privacy@primesourcebp.com.

Information We Collect About You and How We Collect It
We may collect several types of information from and about users of our Website, including information:

By which you may be personally identified, such as name, postal address, e-mail address, telephone number, date of birth, any other identifier by which you may be contacted online or offline (“personal information”);
That is about you but individually does not identify you, such as geographic region and length of time since last visit to our Website; and/or
About your internet connection, the equipment you use to access our Website and usage details.

We may collect this information:
Directly from you when you provide it to us;
Automatically as you navigate through the site, and this information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and/or
From third parties, for example, our business partners.
Information You Provide to Us

The information we collect on or through our Website may include:
Information that you provide by filling in forms on our Website. This includes:
Information provided at the time of registering to use components of our Website, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website; and
Information provided in connection with applications or consideration for employment and contractor opportunities or related on-boarding procedures.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

Your search queries on the Website.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions.
Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website 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 Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. 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 Website. 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 Website.

Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information below.

Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We currently do not respond to Do Not Track requests.

Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

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 Choices About How We Use and Disclose Your Information below.

How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account/subscription, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or any products or services we offer or provide though it.
To allow you to participate in interactive features on our Website.
To market to you.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the order form or registration form on which we collect your data or adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information below.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Policy:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see

Choices About How We Use and Disclose Your Information below.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information

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

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the order form or registration form on which we collect your data. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to legal@primesourcebp.com.
Promotional Offers from the Company. If you do not wish to have your email address or other contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the order form or registration form on which we collect your data. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes, or you can unsubscribe from receiving promotional emails by clicking on an “unsubscribe” hyperlink contained in the emails we send you. Additionally, you may email us at privacy@primesourcebp.com or call 972-999-8555. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by checking the relevant box located on the order form or registration form on which we collect your data. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to privacy@primesourcebp.com. We do not control third parties’ collection or use of your information to serve interest-based advertising. These third parties, however, 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.

Accessing and Correcting Your Information
You can review and change your personal information by logging into the Website and visiting your account profile page.
If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

Your California Privacy Rights
California law permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@primesourcebp.com. At our option, we may respond to such requests by providing instructions about how our users can exercise their options to prevent our disclosure of personal information to third parties for their direct marketing purposes.

California Online Privacy Protection Act. As required by the California Online Privacy Protection Act (“California Act”) and the California Business and Professions Code, this Policy identifies the categories of personally identifiable information (as that term is defined above and in the California Act) that we collect through our Website about individual consumers who use or visit our Website and the categories of third-party persons or entities with whom such personally identifiable information may be shared. See more about the California Act at http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

California Consumer Privacy Act of 2018 (CCPA). You have the right to request, twice a year and free of charge, certain information about parties to whom we have disclosed or sold your personal information in the prior calendar year and a description of the categories of personal information shared. Additionally, upon request, twice a year and free of charge, we shall provide to you any information relating to your personal information and our processing of your personal information in a concise, transparent, intelligible, and easily accessible form using clear and plain language.

To make such a request, please send an email to privacy@primesourcebp.com and please include the phrase “Personal Information Privacy Request” in the subject line, the domain name of the website you are inquiring about, along with your name, address and email address. You also may contact us via our toll-free number at 972-999-8555. You can also ask us to delete your personal data stored on our platform. If we receive a request to delete your data, we will ask you if you want your personal information to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose personal information we have deleted so you may be contacted again by us, should we come into possession of your personal information at a later date.

Requests to know and requests to delete will be honored within 45 days; if more time is needed to respond, we will notify you. If you exercise your rights under the CCPA, we will not discriminate against you.

You can designate an authorized agent to make a request under the CCPA on your behalf if:

The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described above:

Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to privacy@primesourcebp.com; and
Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

We have collected, will collect and have disclosed the personal information described in the categories below during the last year for business purposes; however, we do not sell your personal information. We will respond to your request to opt-out within 15 business days.

Category Examples Collected Disclosed/Sold
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Yes Disclosed for business purposes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Yes Disclosed for business purposes
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Yes Disclosed for business purposes
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes Disclosed for business purposes
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. No No
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes Disclosed for business purposes
G. Geolocation data. Physical location or movements. Yes Disclosed for business purposes
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No No
I. Professional or employment-related information. Current or past job history or performance evaluations. Yes Disclosed for business purposes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Yes Disclosed for businesses purposes
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No No

Your Canadian Privacy Rights
Canadian residents are entitled to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@primesourcebp.com.

Your Vermont Privacy Rights
Vermont law places additional limits on sharing information about Vermont residents. As long as a user remains a resident of Vermont, we will not share information we collect about Vermont residents to companies outside of PrimeSource or to PrimeSource affiliates, except:

To companies that perform marketing or other services on our behalf;
Contact information (like name and address), and transaction information (such as your payment history), with companies we have Joint Marketing Agreements with;
With the authorization or consent of the Vermont resident; or
As permitted or required by law.

Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

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 our Website. 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 Website.

Changes to Our Privacy Policy
It is our Policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Policy to check for any changes.

Contact Information
To ask questions or comment about this Policy and our privacy practices, contact us at privacy@primesourcebp.com.

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