Privacy Policy

This privacy policy (“policy”) describes how Thriving Brands LLC (“we”, “us”, “our”) collects and uses the personal information that you may provide when accessing and using www.rightguard.com. It also describes the choices available to you regarding our use of your personal information, your rights in relation to your personal information, and how you can access and update this information.

1. Personal Information We Collect About You. We may collect and use the following information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”):

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers)
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, address, telephone number, bank account number, or any other financial information.
• Professional or employment-related information, including employment candidacy information, including contact, resume, and salary information as part of submissions for employment opportunities
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

If you do not provide certain personal information, it may delay or prevent us from providing certain services to you.

2. How Your Personal Information is Collected. We collect most of this personal information directly from you when you provide it to us. We may also collect information directly from a third party (e.g., our service providers for the online services and our products and services, marketing and advertising partners).

3. 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, operating system, and browser type.

The information we collect automatically is statistical data that does not contain personal information. Information we collect automatically helps us to improve our Website and to deliver a better service.

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.

We may use third party analytics, including Google Analytics. You can opt out from the use of Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add On.

4. Links to Other Websites. Our Website may contain links to the websites of third parties whose privacy practices may differ from ours. If you submit personal information to any of these third-party sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or link to from our Website.

5. How and Why We Use Your Personal Information. We may use personal information for the following purposes:

• To provide services to you;
• To send you requested information;
• To respond to your requests;
• To comply with our legal and regulatory obligations;
• For our legitimate interests or those of a third party, meaning we have a business or commercial reason to use the personal information; or
• Where you have given consent.

In addition to the foregoing, the table below provides examples of how we may use your personal information and our reasons for such use:

How we may use your personal information	Our reasons
To provide services to you	For the performance of our agreement with you or to comply with your requests
To prevent and detect fraud against you or us	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
Processing necessary to comply with professional, legal and regulatory obligations that apply to our business	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures, so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information; and to comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Updating and enhancing customer records	To comply with our legal and regulatory obligations; and for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Marketing our services and those of selected third parties to: – existing and former customers; – third parties who have previously expressed an interest in our services; – third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

6. How We Share Your Personal Information. We will not sell any of your personal data to any outside organization. We only disclose your personal data to third parties as reasonably necessary to carry out the permitted uses described in this policy. For example, we may share personal data with:

• third parties we use to help us run our business, such as marketing agencies, website hosts, technical and customer support contractors, and other service providers who are required to keep the personal data confidential and are prohibited from using it other than to carry out their services on our behalf;
• our successors in the event of a sale, merger, acquisition, or similar transaction affecting the relevant portion of our business; and
• legal and governmental authorities or other third parties, to the extent required to comply with a legal order or applicable law.

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

• If we believe disclosure is necessary or appropriate to protect our rights, property, or the safety of our company, our customers, or others;
• For any other purpose disclosed by us when you provide the information; or
• With your consent.

In the preceding 12 months, we may have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household:

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, address, telephone number, education, employment, and employment history.
• Professional or employment-related information, including employment candidacy information, including contact, resume, and salary information as part of submissions for employment opportunities
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with the Website, or advertisement)

7. Where Your Personal Information is Held. We are based in the United States, and personal data collected by us worldwide may be transferred to the United States for processing and storage. For example, we may import your personal information into the United States to fulfill our contractual obligations to you. By providing personal information to us, you consent to the transmission of your information outside your own country to be stored in the United States. We take steps to ensure that any such transfer complies with data protection law and that all personal information is secure, including, where appropriate, putting in place standard contractual clauses or implementing other lawful tools and processes for transferring personal information.

8. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;
• To comply with laws and regulations and provide to law enforcement agencies;
• To preserve our business records; and/or
• To conduct our business operations.

9. California Residents. California consumers have the right to request any of the following information from us regarding personal information collected about you during the preceding 12 months:

• The categories of personal information collected about you.
• The categories of sources from which the personal information is collected.
• The business or commercial purpose for collecting or selling personal information.
• The categories of third parties with whom we share personal information, if any.
• The specific personal information collected about you.
• For personal information sold or disclosed to a third party for a business purpose, you have a right to know the categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and the categories of personal information that we disclosed about you for a business purpose.

We will provide this information free of charge up to two (2) times in any twelve (12) month period within 45 days of receiving your verifiable request (including verification of your identity and your California residency), subject to delays and exclusions permitted by law. Specific personal information about you or your account that is categorized as sensitive or confidential may be redacted.

As a California resident, you have the right to request that we delete any personal information that we have collected about you. We will honor this request subject to the range of exclusions permitted by law. For example, we are not required to delete personal information if it is necessary to complete a transaction or reasonably used for an ongoing business relationship or if it is used internally in a lawful manner that is compatible with the context in which the consumer provided the information.

As a California resident, you also have the right to opt out of the sale of your personal information to third parties. We do not sell your personal information. However, we are permitted to share your personal information with a service provider.

We will not discriminate against you if you choose to exercise any of these rights. California residents may exercise the rights described above by contacting us as follows:

Mail:	Thriving Brands, LLC 8170 Corporate Park Drive, Ste. 143 Cincinnati, OH 45242
Email:	privacy@thriving-brands.com (please use “CCPA” in the subject line)

We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request.

10. Keeping Your Personal Information Secure. Although we do our best to protect your personal information, the transmission of information via the internet is unfortunately not completely secure and we cannot provide an absolute guarantee regarding the security of your personal information transmitted to us. Any transmission of personal information is at your own risk.

11. Treatment of Minors’ Information. Our Website is not intended for children and we do not knowingly solicit or collect personal data from children. If we are notified or discover that a child under the age of 13 has submitted personal data to us, we will take reasonable steps to delete the information.

12. Changes to This Privacy Notice. We may update this policy from time to time. We will always post the then-current version of this policy on our Website and will indicate at the top of the policy the date on which the latest version took effect. Please review this policy from time to time to stay updated on our privacy practices.

13. How to Contact Us.

Please contact us if you have any questions about this privacy policy or the information we hold about you.

Mail:	Thriving Brands, LLC 8170 Corporate Park Drive, Ste. 143 Cincinnati, OH 45242
Email:	info@thriving-brands.com

14. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).