Privacy policy

PRIVACY AND DATA PROTECTION

Simply Good Coffee, Inc., (“SGC”, “we” or “us”) is committed to protecting your privacy. This Privacy Policy explains how information about you or associated with you (“personal information” or "personal data") is collected, used, and disclosed by SGC.

This Privacy Policy applies to our websites, including www.SimplyGoodCoffee.com and all related pages and subdomains (collectively, the “Website”), and to your non-public interactions with SGC (e.g., via Customer Service/Support).

For the purposes of applicable data protection laws, SGC Corporation is the controller of personal information we hold about you.

  1. HOW WE COLLECT AND USE INFORMATION
  2. SHARING PERSONAL INFORMATION WITH THIRD PARTIES 

- PERSONAL INFORMATION WE MAY COLLECT FROM DEVICES

- PERSONAL INFORMATION WE MAY COLLECT THROUGH COOKIES & OTHER TRACKING        TECHNOLOGY

  1. YOUR CHOICES REGARDING YOUR INFORMATION 
  2. LINKS TO THIRD PARTY WEBSITES
  3. SECURITY AND STORAGE OF INFORMATION
  4. CHILDREN’S PRIVACY
  5. UPDATES TO THIS POLICY
  6. CONTACTING US

FOR RESIDENTS OF CALIFORNIA

FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA








  1. HOW WE COLLECT AND USE INFORMATION.

We collect personal information from you, third parties, Apps, and certain third-party partner websites that are registered with us as partners to market and showroom the Products and Services we offer, maintain, and provide, to process and ship orders, to provide customer service, to communicate directly with you, to monitor and improve our Service, and to help us develop new products and services.

The categories of information we collect are as follows:  

Information you provide: We collect and store personal information such as your name, email address, username and password, shipping address, billing information, and phone number when you register for an SGC account, shop online, sign up for offers, communicate with us, or otherwise use our Service. Directly identifiable personal information (such as full name and email address) is stored separately with access restricted to need-to-know.

If you register a Product online or through mail or another registration means, we may also collect information about your Product, such as the ID, serial number, or product code. We may also collect personal information when you call us, send us an email, or provide us with comments, chat messages, and opinions on our Website or through our Service. You acknowledge that SGC cannot guarantee the privacy of personal information you choose to post publicly on the internet, including on SGC’s website or social media pages.

Communications: Texts and SMS. When opted-in, you will receive text messages (SMS/MMS) to your mobile number. These kinds of messages may include offers, coupons, or other information. You can opt-out of this service at any time. Just text “STOP” to the phone number. After you text “STOP” to us, we may send you an SMS reply to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time or text “START” or “JOIN” and we will start sending SMS messages to you again. If you are experiencing any issues, you can reply with the keyword “HELP”. Or, you can get help directly from us: https://simplygoodcoffee.com/pages/contact-customer. Carriers, such as AT&T, are not liable for delayed or undelivered messages. Message and data rates may apply for any messages sent to you from us and to us from you. You should expect to receive 1-10 messages per month from us. If you have any questions about your text plan or data plan, please contact your wireless provider. This communication is necessary for our legitimate interests, namely to inform you of our direct marketing and updates on orders processed and to be responsive to your needs and requests.

Information we receive from third parties.  If you login to our Website or Apps through a third party social network or authentication service, these services will authenticate your identity and may share your personal information with us (such as your name, email address, and profile information). Similarly, we may receive certain personal information if you interact with our accounts on a social network, such as by “Liking” or “Following.” The data we receive from these third-party services is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Service.

We use this information to operate, maintain, and provide to you the features and functionality of the Service, to process and ship orders, to provide customer service, and to communicate directly with you, to monitor and improve our Service, and to help us develop new products and services.

Information We Collect from Registered Products Equipped with Smart Technology. Some of our Products may be equipped with smart technology which allows the Products to transmit data wirelessly to the Service. Product data is stored in a deidentified state (separated from identifiable information) Product and App usage data. When you register your Product with the SGC App, we collect information about the Product, such as a Product name and device number, and information about the Product and/or App usage, such as battery life and health.

App information. Through the SGC App as potentially available in the future, you may opt-in to connect your SGC account with SGC smart home partners. Doing so will allow SGC to scan your device for smart home apps in order to suggest smart home connections. SGC will not collect this information unless you opt-in, and you may opt-out at any time through the SGC App. Should you choose to opt-in, App, meaning the names of smart home partner apps you have downloaded, will be stored in a deidentified manner.

Identification information, such as your national identity card or other proof of identity. We may use this information to issue invoices for certain tax or legally required documents as needed. The processing is necessary to comply with a legal obligation to which we are subject. We may request this information for account validation purposes when fulfilling your rights under applicable law, for example, if you request a portable copy of your personal information. The processing is necessary to comply with a legal obligation to which we are subject.

[California Customer Records (Cal. Civ. Code §1798.80(e))] Customer Records, such as contact information and payment information. We use this information to facilitate transactions and provide you with the Service. The processing is necessary for the performance of a contract with you. We use this information to provide customer support. The processing is necessary for our legitimate interests, namely administering the Service. We use this information to detect and prevent fraud. The processing is necessary for our legitimate interests, namely the detection and prevention of fraud.

Demographic information, such as your age, date of birth and gender. We may collect this information in optional surveys in order to develop new products and features available through our Service or otherwise improve our Service. The processing is necessary for our legitimate interests, namely developing and improving our Service and to inform our product development. We may collect this information in optional surveys in order to determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing.

Purchase and transaction information such as products purchased. If you register your device with us, we will also collect information about your Product such as Product ID, serial number or product code. We use this information to process and ship orders. The processing is necessary for the performance of a contract between you and us. We use this information to provide customer service, including dealing with any enquiries or complaints. The processing is necessary for our legitimate interests, namely administering, developing and improving our Service. We use this information to process returns or repairs. The processing is necessary for the performance of a contract between you and us. We use this information to determine products and services that may be of interest to you and to inform our product development. The processing is necessary for our legitimate interests, namely informing our direct marketing and product development.

Payment and billing information, such as your credit or debit card information, your billing address and purchase history. We use this information to process and ship orders. The processing is necessary for the performance of a contract between you and us. We use this information to detect and prevent fraud. The processing is necessary for our legitimate interests, namely the detection and prevention of fraud.

Referral and web traffic information such as when you come to our site from another site, when you click on a link or when another site sends you to our site or app. The processing is necessary for the performance of a contract between an affiliate, partner, referrer or other third party who is in a contract with us and may deserve a payment, fee or commission. you and us. We use this information to detect who might be owed a payment from us, as determined by us.

Geolocation - approximate location such as the time zone in which your Product is located. We will not collect or track your precise location, including GPS coordinates, without your permission. If this information is ever required for a given feature, you will be able to opt in and out via the SGC App. We may use this information to ensure that the content on our Service is relevant to you, to provide new location-based features, and to help us provide customer service, including processing returns or repairs or providing a payment of fee to a partner as we determine might be due, by location. The processing is necessary for our legitimate interest, namely to tailor our Service to the user and to improve our Service generally.

Consumer behavior such as products purchased, motivation for purchase, and other purchasing behavior and preferences. We use this information to develop new products and features available through our Service or otherwise improve our Service. The processing is necessary for our legitimate interests, namely developing and improving our Service and to inform our product development. We use this information to determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing.

Demographic and lifestyle information, such as your leisure and other interests, number of children and number of pets, information about your home environment, and salary or other income information. We may collect this information in optional user surveys in order to develop new products and features available through our Service or otherwise improve our Service. The processing is necessary for our legitimate interests, namely developing and improving our Service and to inform our product development We may collect this information in optional user surveys in order to determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing.

Comments, chat and opinions that you provide to us when you contact us directly, such as the content of any text messages or emails you send to us, or phone calls.  We use this information to provide customer service, including dealing with any enquiries or complaints. The processing is necessary for our legitimate interests, namely communicating with users and addressing users' comments and complaints. We use this information in connection with processing returns or repairs or rendering customer service/satisfaction. The processing is necessary for the performance of a contract between you and us. We use this information to develop new products and features available through our Service or otherwise improve our Service. The processing is necessary for our legitimate interests, namely developing and improving our Service and to inform our product development. We use this information to determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing.

Information received from third parties, such as social networks. If you connect a social network to our Service, or interact with our Service through a social network, we may receive information from the social network such as your name, profile information, and any other information you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network.

We use this information to allow you to log-in to the Service and to tailor how the Service is presented to you. The processing is necessary for our legitimate interest, namely to tailor our Service to the user. We use this information to communicate with you and to respond to your enquiries. The processing is necessary for our legitimate interest, namely to communicate with users.

Preferences set for notifications, marketing communications, how our Website or Apps are displayed and how you use the Service. We use this information to display our Service to you in accordance with your preferences. The processing is necessary for the performance of a contract between you and us. We use this information to provide only the notifications and to send only the marketing communications that you have agreed to receive. The processing is necessary for compliance with a legal obligation to which we are subject.

Knowledge of the Apps on Your Phone. If you opt in, we may collect the names and app IDs of the smart home apps on your phone. We use this information to surface personalized recommendations for smart home integrations and voice automations, and to prioritize future automation partners. The lawful basis of processing is consent. The processing is necessary to tailor the Service to the user, and to develop new products and features. 

Other device Information. If you opt into certain features, we may collect device data, such as MAC address, device type, device name, identifier, serial number, product code, network bandwidth usage, and device location within and near the home.  We use this information to operate, maintain, and provide to you the features and functionality of the Service. The processing is necessary for the performance of a contract between you and us.

We use this information to develop new products and features available through our Service or otherwise improve our Service. This processing is necessary for our legitimate interests, namely new product and feature development, and improving the Services. We use this information to determine products and services that may be of interest to you and to inform our product development. This processing is necessary for our legitimate interests, namely new product and feature development, and more personalized Services.

Other location and use information. We use this information to diagnose and fix technology problems. The processing is necessary for the performance of a contract between you and us and to take steps prior to entering into a contract between you and us. We use this information to tailor our Service in particular by improving the quality of the map that is generated and used by your Product to allow it to operate effectively, and to develop new products and features available through our Service. The processing is necessary for our legitimate interests, namely tailoring our Service to users, and developing new products and features.  We use this information to develop new products and features available through our Service. The processing is necessary for our legitimate interests, namely developing new products and features on the Service. We use this information to provide certain features and functionalities of the device. The processing is necessary for the performance of a contract between you and us and to take steps prior to entering into a contract between you and us. The lawful basis of processing this data is consent. 

Our Products do not transmit this information unless if this feature is available, you register your Product online and connect to Wi-Fi or Bluetooth, or connect to the internet via another method. It is possible to use our smart technology Products without Wi-Fi or Bluetooth data transmission, simply by disconnecting your Wi-Fi or Bluetooth from the Product or by never connecting it at all. You may also choose through your settings in the App not to have data transmitted to us.

Use of Cookies and Other Technologies to Collect Information.  

We and our third-party service providers may collect certain types of usage information when you visit our Website or use our Apps, read our emails, or otherwise engage with us. We use this information to enhance and personalize your user experience, carry out interest-based advertising and marketing, to monitor and improve our Website and Service, and for other internal purposes. In some instances, we and our third-party service providers may combine this usage information with personal information. If we do combine any usage information with personal information, the combined information will be treated by us as personal information.

We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”). Below lists the categories of personal information we collect about you automatically and how we use that information. SGC complies with applicable laws related to cookies and other tracking technologies.

Cookies. 

Cookies are text files that are placed on your computer or other mobile or handheld device (such as smartphones or tablets) when you visit certain pages on the internet. They are used to “remember” when your computer or device accesses a website.

We use the following types of cookies: (i) Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into areas of our Website and to add items into your shopping basket. (ii) Functionality cookies. These are used to recognize you when you return to our Website so that we can offer you a better shopping experience on this Website. For instance, this enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). (iii) Analytical / performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily. (iv) Targeting cookies. These cookies enable us to collect information that we can use to make our Website and the advertising displayed on it, and the marketing messages we send to you more relevant to your interests. We may also share this information with third parties who provide a service to us for this purpose.


Google Analytics and Advertising.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Website and Apps. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by vising NAI’s online resources at https://optout.networkadvertising.org.

Please be aware that advertisers and other third parties may use their own cookie tags when you click on an advertisement or link on our website. These third parties are responsible for setting out their own cookie and privacy policies. Some jurisdictions require prior, opt-in consent before non-essential cookies may load. We comply with applicable regulations and allow all website visitors to opt in or out of cookies and other trackers from within our cookie consent banner settings. For all cookie tracking described in this section, including Google Analytics, SGC complies fully with your opt-in or opt-out preferences managed via the cookie banner that appears when you first visit our Website. If you would like to reset your preferences via the banner, you may do so by clearing your cookies and relaunching our Website. Furthermore, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain 

These settings will typically be found in the "options" or "preferences" menu of your browser. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit https://allaboutcookies.org. To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:

-Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (https://optout.aboutads.info/) and mobile application-based ” AppChoices” download page (https://youradchoices.com/appchoices)

-European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page (https://youronlinechoices.eu)

-Network Advertising Initiative(NAI)’s self-regulatory opt-out page (https://optout.networkadvertising.org ).

Please note that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers, or delete the opt-out cookies, you may need to perform the opt-out task again. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

For mobile users, you have controls in your device Operating System that enable you to choose whether to allow cookies or share your advertising ID with companies like SGC or our advertising service providers. To block the IDFA on your iOS mobile device, you should follow this path: Settings > General > About > Advertising and then turn on ‘Limit Ad Tracking’. To block Android ID on your Android device, you should follow this path: Google Settings > Ads and then turn on ‘Opt Out of Ads Personalization’.

PERSONAL INFORMATION WE MAY COLLECT FROM COOKIES AND OTHER TRACKING TECHNOLOGY

Information about how you access and use the Service.  Network activity information - For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Service, the time you access our Service and how long you use it for, the approximate location that you access the Service from, whether you access the Service from multiple devices, the links you click when browsing our Service or when you receive communications from us, and other actions you take on the Service. We use this information to present our Service to you on your device. The processing is necessary for the performance of a contract between you and us. We use this information to tailor how our Service is presented to you. The processing is necessary for our legitimate interests, namely to tailor our Service to the user. We use this information to determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing. We use this information to monitor and improve our Service and business, including diagnosing and fixing technology problems and developing new products and services. The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Service and to improve our Service generally.

Network activity information Information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Service. This information can include details about the type of device, model and manufacturer, unique device identifying numbers (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), mobile carrier, mobile device operating system brand and model and phone number, browsers and applications connected to our Service through the device, your Internet service provider, your IP address and your device’s telephone number (if it has one). We use this information to present our Service to you on your device. The processing is necessary for the performance of a contract between you and us. We use this information to tailor how our Service is presented to you. The processing is necessary for our legitimate interests, namely to tailor our Service to the user. We use this information to determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing. We use this information to monitor and improve our Service and business, including diagnosing and fixing technology problems and developing new products and services. The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Service and to improve our Service generally.




  1. SHARING PERSONAL INFORMATION WITH THIRD PARTIES 

We may share your personal information in the instances described below.  For further information on your choices regarding your information, see the "Your Choices Regarding Your Information" section. 

Group companies. Other companies owned by or under common ownership as SGC, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Policy.

Service providers. Vendors, affiliates, showroomers, commission partners, and other service providers that perform services on our behalf, solely in order to carry out their work for us, which may include identifying and serving targeted advertisements, providing e-commerce services, content or service fulfillment, billing, website operation, payment processing and authorization, customer service, fraud prevention, web hosting, data storage, or providing analytics services.

Third parties at your request. SGC might permit third parties to develop apps and tools that interact with our Products and Service in the future, including, for example, Amazon Alexa and Google Assistant. If you choose to integrate a third-party app or service with our Products or Service, we will permit the third party to collect information from your Product and App necessary to power the integration. Please note that SGC does not control the data collection and use practices of these third parties. You should carefully review the third-party privacy policy and other documents before connecting your Product or the Apps to the third-party service. You may opt in or out of a third-party app or service integration at any time. After opting out, information transfers to that third-party will cease unless and until you opt-in again.

Purchasers and third parties in connection with a business transaction. Other parties in connection with any company transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of bankruptcy or related or similar proceedings; and Law enforcement, regulators and other parties for legal reasons. Third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process, or other government request, (ii) enforce our Terms of Use Agreement, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of SGC, its users, or the public as required or permitted by law, and (v) detect, prevent, or otherwise address criminal (including fraud or stalking), security, or technical issues.

We may also share information with others in an aggregated and anonymous form that cannot reasonably identify you as an individual. 

  1. YOUR CHOICES REGARDING YOUR INFORMATION

Access, correct, and update personal information. You may access, correct, remove, request deletion of, and update certain personal information that you have provided to us by clicking on “My Account” on our Website and App. Depending on your jurisdiction, you may be entitled to additional rights in relation to your personal information.

FOR RESIDENTS OF CALIFORNIA

FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA

Marketing communications. You may control your communication preferences through the “My Account” page on our Website or App. You may also click the “unsubscribe” button on any promotional email communication we send you. Note that you may not be able to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, order confirmations, changes or updates to features of the Service, or technical and security notices.

Device Collection. You may be able to control or stop the collection of certain usage data from your registered Product through the App, for example when you opt in or out of certain features. For features that require you to opt-in before collecting device or usage data, opting out of the feature will immediately halt any future data collection related to that feature. You may also control or stop the collection of usage data from your registered Product by disconnecting your Product from Wi-Fi or Bluetooth via the App. Please contact us at brew@simplygoodcoffee.com if you have questions about disconnecting your Product.

Online advertising. You may be able to avoid the collection of information through some cookies or other tracking technologies by actively managing the settings on your browser or mobile device. Please refer to the "Use of Cookies and Other Technologies to Collect Information" section to learn about disabling or blocking cookies and tracking technologies.

  1. LINKS TO THIRD PARTY WEBSITES

The Service may, from time to time, contain links to and from third party websites of our partner networks, advertisers, partner merchants, retailers, and affiliates and, within this Privacy Policy, links to websites of third-party organizations for information purposes. If you follow a link to any of these websites, please note that these websites have their own terms of use and privacy policies and that we do not accept any responsibility or liability for their services or practices. Please check the individual terms and policies before you submit any information to those websites. Additionally, our Websites may include social media features such as Facebook, Twitter and Pinterest buttons (such as “Like,” “Tweet” or “Pin”). Your interactions with these features are governed by the privacy policy of the company providing the feature, not by our Privacy Policy. Please review your privacy settings on the applicable social media sites. Depending on your cookie/tracking settings, these social media sites may automatically record information about your browsing behavior every time you visit a site that has a social media button, regardless of whether you click on the button

  1. SECURITY AND STORAGE INFORMATION

Security.  SGC prioritizes the security of your information and uses physical, administrative, and technological safeguards to help to preserve the integrity and security of all information we collect, including what we share with our service providers. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any of your personal information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised, in accordance with any applicable laws and regulations. If you become aware of any loss, theft, or unauthorized use of your password, please contact us at brew@simplygoodcoffee.com or by phone at 877-355-5684.

 Transfer and storage.  SGC may process your personal information outside the country you are in, including in the United States. Please be advised that United States law, or the laws of any other jurisdiction where we or our service providers process your personal information, may not offer the same privacy protections as the law of your jurisdiction.

Data Retention. SGC will retain personal information for as long as it is necessary for the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) whether we have a current or ongoing relationship with a user and are actively providing the Service; (ii) whether the personal information has been deidentified; (iii) whether there is a legal or compliance obligation to which we are subject; or (iv) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations). You may contact us at brew@simplygoodcoffee.com, through the SGC App, or by logging into your account on our Website to request your personal information be deleted from our systems. We reserve the right to anonymize your personal data, including information about Product and Service usage, and to retain anonymized information for our own records and for product and feature development purposes. Anonymized information cannot be associated with you as an identifiable individual. If you wish to enquire further about the safeguards we use, please contact us using the details set out in 

  1. CHILDREN’S PRIVACY

The Service, Products, and App are not directed to persons under 16 and we do not intentionally collect or maintain information from persons under 16. If you become aware that personal information about a person under 16 has been provided to us, please immediately contact us using the details below.

  1. UPDATES TO THIS POLICY

We reserve the right to modify this Privacy Policy from time to time. If we make any changes to this Privacy Policy, we will change the “Last Revision” date and will post the updated Privacy Policy on this page

  1. CONTACTING US

If you have questions or comments about this Policy or our privacy practices, please contact us at Brew@SimplyGoodCoffee.com 

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

FOR RESIDENTS OF CALIFORNIA

This California Privacy Notice (“California Notice”) applies to California residents whose personal information is processed by SGC pursuant to the California Consumer Privacy Act (“CCPA”) or other California privacy laws described below. The California Notice describes how we protect the personal information we process and control relating to California residents and rights California residents may have in relation to their personal information. For the purposes of this California Notice, “personal information” has the meaning provided by the CCPA and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with you, or that is excluded from the CCPA’s scope, such as personal information covered by certain sector-specific US privacy laws, such as HIPAA, the FCRA, GLBA, or the Driver's Privacy Protection Act of 1994.

Collection and use of personal information. We collect personal information from and about you as described in section 1 above. To learn more about the categories of personal information we collect and how we use or intend to this information below. 

Disclosure of personal information. We share personal information with service providers (as defined in the CCPA), and with third parties for business purposes, in a manner that does not constitute a “sale” (as defined in the CCPA (for example, at the direction of the consumer). To learn more about how we disclose data to third parties, please refer to “Sharing Personal Information with Third Parties”. We allow certain third-party advertising partners to collect information about the users of our Service for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting. All cookies that are not strictly necessary (including third-party) require prior, opt-in consent from California consumers, are loaded per the consumer’s instructions and preferences, and do not involve “sales” of personal information. To learn more about online advertising and how you may be able to control some of this activity, please refer to “Third-Party Tracking and Online Advertising” .

Your California Rights and Choices. As a California resident, you may be able to exercise the following rights:

The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

The specific pieces of personal information we have collected about you;

The categories of personal information we have collected about you;

The categories of sources of the personal information;

The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;

The categories of personal information we have sold and the categories of third parties to whom the information was sold; and

The business or commercial purposes for collecting or selling the personal information.

The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.

The Right to Opt Out of Personal Information Sales to third parties now or in the future. SGC does not sell personal information.

You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights may limit our ability to process personal information. For example, if you submit a deletion request, we may no longer be able to provide you our products and services or engage with you in the same manner.

To submit your California Consumer Rights Requests. You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

To exercise your California Consumer Rights, please submit a request by contacting us using the information provided in the "Contacting Us" section above. You can view and request deletion of your account information by following the instructions on our Customer Care website.

Do Not Sell My Personal Information. SGC does not sell personal information.

California’s “Shine the Light” Law. California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. SGC does not disclose personal information to third parties for their direct marketing purposes, unless the customer first affirmatively agrees to that disclosure. Return to “Your Choices Regarding Your Information”.

FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA, UK OR SWITZERLAND

Data subject rights. If you are an individual located in the European Economic Area ("EEA"), UK or Switzerland, you have the following rights in relation to your personal information: (i) the right to be informed about how your personal information is being used;

(ii) the right to access the personal information we hold about you and, in certain circumstances, to transfer the personal data you have provided to us to another controller in a structured, commonly used, machine-readable format;

(iii) the right to request the correction of inaccurate or incomplete personal data we hold about you without undue delay;

(iv) the right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed, or where consent has been withdrawn (when consent is used as a lawful basis of data processing);

(v) the right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information; and

(vi) the right to object. You have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

(vii) You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

To otherwise exercise your rights, or if you have any questions relating to your rights, please contact us using the details set out in the “Contacting Us” section. You can view and request deletion of your account information by following the instructions on our Customer Care website.

Onward Transfers (Transfers to Third Parties). SGC may transfer personal information to certain third parties (as described in this Privacy Policy). Where we transfer personal information to a third party, we will take reasonable and appropriate steps to ensure the third-party processes personal information for limited and specified purposes and in a manner consistent with our legal obligations.

We allow certain third-party advertising partners to collect information about the users of our Service for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting. All cookies that are not strictly necessary (including third-party) require prior, opt-in consent from individuals in the EEA, UK, and Switzerland before loading. To learn more about online advertising and how you may be able to control some of this activity, please refer to “Third-Party Tracking and Online Advertising”


LAST REVISION DATE: August 5, 2022