PTS Corp. Privacy Policy

1. Effective Date: January 1, 2020

Last Updated: November 1, 2023

This Privacy Policy governs the manner in which PTS Corp. and any of its subsidiaries or affiliates (collectively, “PTS”, “us”, “our”, or “we”) collect, use, maintain, and disclose Personal Information collected when users (“you,” “your”) visit this website and the websites controlled by us, as well as any mobile applications, services, programs, or features (collectively, the “PTS Platform”) owned or operated by PTS. This Privacy Policy (“Privacy Policy”) applies to the PTS Platform and communications generated via the PTS Platform. This Privacy Policy also applies when you interact with us offline. For example, if you provide your contact information to us or interact with us in a retail store or live event, this Privacy Policy applies. Our goal is to help you understand what information we collect about you and describe how we use that information. Please read this Privacy Policy thoroughly so that you understand our privacy practices.

This Privacy Policy is part of our Terms of Use https://www.ptsgrows.com/terms , which governs your use of the PTS Platform. By providing Personal Information to us or by using the PTS Platform, you acknowledge that you agree to be bound and abide by Privacy Policy and the Terms of Use, and you are consenting to the collection, use, and disclosure of that information in accordance with this Privacy Policy. The PTS Platform and the information provided in this Policy is solely intended for residents within the United States of America. If you do not feel comfortable with any part of this Privacy Policy or our Terms of Use, you should stop using or accessing the PTS Platform and opt-out of any marketing focused text messaging or e-mails (via directions provided through the PTS Platform and/or each individual text or e-mail service). Any terms not defined in this Privacy Policy will have the meaning given to them in our Terms of Use.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or household. We do not consider Personal Information to include information that has been aggregated or de-identified so that it does not allow a third party to easily identify a specific individual.

2. Use by Minors

This Site is intended for persons 21 years of age and older. We do not knowingly collect information from individuals under 21 years of age, children, or minors.

If you learn that your child or minor under your guardianship has provided us with Personal Information without your consent, you may alert us at privacy@ptsgrows.com. If we learn that we have collected any Personal Information from anyone under 21, we will quickly take steps to delete such information.

3. Personal Information We Collect

The information we collect falls into three categories: (1) information you voluntarily supply us when you visit the PTS Platform or retail stores, or otherwise interact with us, and submit your information, such as via a contact form or as part of transaction; (2) tracking information gathered as you visit the PTS Platform or retail stores; and (3) information you give us permission to get from a third-party source.

Personal Information You Provide

The following Personal Information about you may be collected when you interact with us or use the PTS Platform or visit our retail stores:

Name

Date of Birth

Demographic information (including age and gender)

Driver’s License or Other Government ID Number

Address

Account credentials

Purchase information/spending habits (including billing address and payment details)

Email address

Phone number

Website or Social Media information

Medical, professional, and educational details (e.g., medical school, specialty)

Health information (e.g., prescription number)

Job or Occupation

Income / Salary

Consumption preferences

This information may be supplied by you in response to specific questions, when you make purchases, sign up for newsletters or other communications from us, or communicate with us by email, text/SMS, phone or in person. You can always refuse to supply Personal Information in response to requests, except that it may prevent you from engaging in transactions, PTS Platform-related activities or receiving responses to your questions/inquiries or other information of interest such as customer programs. Information that is optional at these collection points will generally be noted and marked accordingly.

Additionally, we ask that you do not send us any sensitive Personal Information about yourself or others (e.g., Social Security numbers, biometric or genetic data for the purpose of uniquely identifying an individual, political opinions or beliefs, religion, religious or philosophical beliefs, information related to racial or ethnic origin, sex life or sexual orientation, criminal background, or trade union membership) on or through the PTS Platform.

Call and Text Information

We may work with third-party partners to facilitate phone calls and text messages. We collect information about such communications, including the date and time of the call or SMS message, the parties’ phone numbers, and the content of any SMS messages. This helps us provide and optimize our services and the PTS Platform. Data and message fees may apply.

Applicant Data

When you apply to a job with PTS or one of its licensed retailers, you may provide us with information about you to help us determine whether you are a good candidate for the role you are applying for. Such information may include your name, phone number, email, resume/CV, availability, references, and more.

Cookies and Tracking Technologies

Cookies are small files that are stored on the device you use to access the PTS Platform. Your web browsers place cookies on their hard drives for record-keeping purposes and sometimes to track information about them.

You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you adjust your settings to refuse cookies, or if you delete cookies, you may not be able to access or use some portions of the PTS Platform and some features may not work as intended.

The PTS Platform uses first party cookies (set by PTS) and third party cookies (set by web analytics partners). The cookies used on the PTS Platform may be persistent or session based. A session cookie is a piece of information that is enabled only during a particular Site session. Session cookie files are deleted after logging off the internet browser or powering off your computer. On the other hand, a persistent cookie is not deleted after logging off an internet browser or powering off your computer, but “persists” or continues between sessions. Both types of cookies provide statistical data as well as help make improvements to the PTS Platform.

The PTS Platform may also use other technologies, including but not limited, to Javascript tags or tracking pixels to collect, process, and store browsing information as described above. Tracking pixels and tags assist in delivering cookies and allow us to collect browsing information about you. Tracking pixels or tags may also be included in the emails we send you in order to determine whether the emails have been opened and if you have clicked on links with the email.

The PTS Platform does not respond to browser Do Not Track (DNT) signals.

Passive Information Collection

We may use third party analytics tools, to help us measure traffic, usage, and sales trends by your use of the PTS Platform. These tools use various technologies, including cookies or similar technologies, to collect certain information sent by your devices to the PTS Platform, including:

Your browser name,

The pages you visit on the PTS Platform,

Whether you have previously accessed the PTS Platform,

The IP (Internet Protocol) address for your computer

Demographic data about you,

The type of computer and technical information about your means of connection to the PTS Platform, (e.g. internet service providers and operating system), and

Navigational Data, also known as log files, server logs or clickstream data.

In addition, the laws of certain states requires that we capture CCTV footage within certain retail stores. This footage will include images of all customers who enter and interact with us in those retail stores.

4. How we use Personal Information

PTS may collect and use Personal Information for the following purposes:

To complete transaction requests and improve our services for you: If you make a purchase at a retail location, we will collect the information required to process and complete your orders or respond to any of your customer service requests. This may include your name, credit or debit card number (if applicable), card type, expiration date, and security code. In addition, PTS may use information collected during these transactions to analyze and enhance our services. In conducting these activities, PTS does not store, archive, or otherwise retain credit card numbers.

To respond to your requests and improve our services for you: Information you provide helps us respond to your questions and requests more effectively.

To communicate with you: We may send you information about topics we think may be of interest to you, such as marketing activities, upon your request or otherwise as consistent with this Privacy Policy.

To send periodic emails: We may use your provided email address to send you information and updates. We may also use this information to respond to your inquiries, questions, and/or other requests.

To personalize the user experience: We may use information in its totality to understand how our users, as a collective, use the PTS Platform.

To improve the PTS Platform: We may use information we have collected to enhance the PTS Platform or our other services.

To comply with legal and regulatory obligations: We may use information we have collected to enforce our Terms of Use, prevent or respond to fraud, and fulfill legal obligations, such as conducting CCTV monitoring of certain retail locations and responding to court orders, subpoenas, or any other government requests.

To determine whether you are a good candidate for the role you applied for: We may use information to better understand your candidacy.

To detect, prevent, or mitigate fraud or any other suspicious activities: We may use your information to keep the PTS platform safe.

Additionally we may use your information to: conduct research and development, such as by doncuting voluntary user surveys or obtaining other feedback from you; create aggregated, de-identified and/or anonymized data; support public health and safety efforts; or as otherwise provided in this Privacy Policy or in any other notices we have or will provide to you.

5. How we protect your information

We seek to use commercially reasonable data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, release/disclosure, or destruction of your Personal Information under our control, in accordance with this Privacy Policy. However, the Internet is not 100% secure or error free. Thus, we cannot promise that your use of the PTS Platform will be completely safe, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. We encourage you to be cautious when using the Internet.

By using the PTS Platform or providing Personal Information to us, you agree that we may communicate with you electronically regarding administrative, security, and privacy issues relating to your use of the PTS Platform. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the PTS Platform or sending an email to you. You may have a legal right to receive this notice in writing. If you have any questions or concerns, please notify us at privacy@ptsgrows.com.

6. Sharing your personal information

We do not sell, trade, or otherwise monetize your Personal Information to others.

We may share the categories of Personal Information described above with third parties we partner with and service providers to assist us in certain functions, including providing you with our services and products, providing technological support/assistance and performing security and anti-fraud services, and providing you with communications and marketing information on our behalf. These third parties may have access to your Personal Information only to perform particular tasks on our behalf and are obligated not to disclose or use your Personal Information for any other purpose.

These service providers and third parties can be classified in the following categories:

Delivery partners, to deliver our products to the right location;

Financial partners involved in the processing of your banking or credit card data in retail locations;

Marketing partners, which we may use to send you marketing related communications, for instance any applicable promotions, contests, newsletters, and surveys;

IT service providers, such as our data hosting provider(s) and companies we employ to manage the PTS Platform and to provide services for the PTS Platform and/or to assist us in analyzing how the PTS Platform is used;

Other service providers that we may utilize to provide services to us or on our behalf.

Your Personal Information may be disclosed to a third party if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal proceeding or investigation. Your Personal Information may also be disclosed to a third party if the disclosure is appropriately related to the potential or actual sale or other disposition of all or part of our business or assets.

We may disclose aggregated or de-identified information with third-party partners, affiliates, or service providers for the purposes outlined above.

We may use third-party services to collect, monitor, and analyze information as described above. Those third-party service providers have their own privacy policies addressing how they use such information.

7. Privacy Rights

California Residents

California Shine the Light law

PTS does not share Personal Information (as defined by California Civil Code §1798.83) with other people or non-affiliated businesses for their direct marketing purposes.

If you are a California resident, this section applies to you. For purposes of this section, “personal information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”), but does not include certain de-identified or aggregated information, information publicly available in government records, or certain information excluded from the CCPA’s scope.

As a California resident, you are entitled to certain privacy rights further explained below. These rights are not absolute and are subject to exceptions. We may be required or permitted by law to decline your request. When requesting to exercise your right to access and deletion under the CCPA, only you, a person that you authorize to act on your behalf, or an entity registered with the California Secretary of State that you authorize to act on your behalf, may make such a verifiable request.

The right to request a copy of the categories of personal information and specific personal information collected about you in the last 12 months. To do so, please email: privacy@ptsgrows.com.

The right to delete personal information collected from you, except as necessary to comply with legal obligations, detect, prevent and mitigate security incidents, bugs or fraudulent, malicious, deceptive or illegal activity, or as otherwise provided under applicable law.

The right not to have your personal information sold to third parties, if applicable. PTS does not sell your name, address, government identification, medical recommendation or identification, or other similar personal information. However, California law broadly defines what constitutes “personal information” such that cookie and technical information shared with targeted advertising vendors may constitute a “sale” of “personal information.”

The right not to be discriminated against for exercising your privacy rights described above.

For privacy and security purposes, we are required to verify your request before we fulfill your request.

If you are an authorized representative, we will require you to verify your identity or the validity of your representation before fulfilling your request for privacy and security purposes. To verify your identity or representation, we may ask for you to share data points as described in this Privacy Policy to be able to look up your data and ensure you are who you claim to be. You may also be required to provide us with a signed declaration under penalty of perjury.

In addition, if you are an authorized representative, we may request: a copy of your valid government-issued identification or other proof of identity acceptable to us in our sole discretion; and, a power of attorney pursuant to California Probate Code sections 4000 – 4465 or as otherwise sufficient in our discretion to establish your authority as an authorized representative.

You may contact us at privacy@ptsgrows.com with any authorized representative requests, or if you have questions or concerns about our privacy practices or your rights.

Consumer Rights Request Process

When you make a request, we may require that you provide certain information and follow procedures in order for us to can verify the request and your jurisdiction prior to responding to it. The verification steps we take may differ depending on the type of request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we are unable to verify your request, we may ask you for additional information in order for us to then verify your request.

Consumers will be required to submit the following: their first and last name and email address. Consumers may also be asked to provide their telephone number or address so that we can verify such request. Please provide as much of the requested information as possible so that we may verify the request. We will only use the information received in a request for the purposes of responding to the request.

You may submit a privacy rights request to us by:

Calling us at 877-597-8521.

Emailing us at privacy@ptsgrows.com.

No Sale of Personal Information

We are not currently selling your Personal Information nor have we sold your Personal Information since January 1, 2020, the date the CCPA went into effect.

Updating Your Information

In order to keep your Personal Information current and accurate, please contact us as specified above. If you decide to email us, please include the words “Updating Personal Information Request” in the subject line.

We will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted via the PTS Platform.

8. Updated Uses of Personal Information

From time to time and on occasion, we may choose to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices are adjusted regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected such information, we will make reasonable efforts to give notice and obtain consent to any such uses as may be required by law.

9. Data Retention

We will retain your information for as long as required in order to provide you the PTS Platform’s services, as necessary to comply with our legal obligations, resolve disputes, defend our legal rights, and enforce our agreements, and for PTS’s valid business purposes.

10. Third party websites

The PTS Platform may contain links to sites of third parties. We do not control the content or links that appear on these sites and are, thus, not responsible for these sites or the information contained therein. These sites may have their own privacy policies and terms of use. Accordingly, any interaction or browsing on any other website, including websites which have a link to the PTS Platform, is subject to that website’s own terms and policies.

11. Changes to this Privacy Policy

PTS has the discretion to update or change this Privacy Policy at any time. If we make any change in how we utilize Personal Information, we will notify you via email (if you have provided your email address to us) or by means of a notice on the PTS Platform. Any changes shall become effective when the revised Privacy Policy is posted on the PTS Platform. Your use of the PTS Platform following these changes means that you accept the revised Privacy Policy. We advise that you regularly review the Privacy Policy when you visit the PTS Platform. This Policy was last updated November 1, 2023.

12. Contacting Us

PTS Corp., located at PO Box 1781, Arlington Heights, Illinois 60006 (phone number 877-597-8521), is the company responsible for the collection, use maintenance and disclosure of Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us via the contact form on our Contact Us page or please write to the following address and/or email:

PTS Corp.

PO Box 1781

Arlington Heights, IL 60006

privacy@PTSgrows.com