Privacy Policy

Last Updated: February 2025

GROUP B USA, LLC ("Group B", "we", "us", "our") is committed to protecting the privacy and security of the personal information we collect and wants you to be familiar with how we collect, process, and disclose your personal information. This privacy policy (the "Privacy Policy") describes our policies and practices for handling personal information that we collect from or about you both online and offline. It applies to the websites (the "Websites"), the software applications (the "Apps"), the social media pages (collectively, our "Social Media Pages"), email messages that we operate, and any other tools or locations that link to this Privacy Policy (collectively the "Services").

1. PERSONAL INFORMATION WE COLLECT

Information you provide directly to us. We may collect the following categories of personal information including when you use and interact with our Services, complete surveys or other online forms, or communicate with us:

• Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, and email address;
• Demographic information, including age and gender;
• Commercial information, such as account or credit card number, products purchased, or other purchasing or consuming histories or activity;
• Geolocation or precise geolocation data, including information derived from your GPS, WiFi, Bluetooth signals, Internet Protocol ("IP") address, and other device information;
• Device information, such as type of device, operating system, IP address, and device identifiers;
• Internet or other electronic network activity information, such as browsing history, search history, and information regarding your interaction with an internet website application, or advertisement; and
• Inferences drawn from any of this personal information, such as your favorite products or your communications preferences.

Information we collect automatically. We may automatically collect internet, electronic activity, and other information from the devices and browsers that you use, including your device type; domain server; IP address; device and advertising identifiers, probabilistic identifiers, and other unique personal or online identifiers; time zone setting and location; browser type and version; browser plug in types and versions; operating system and platform; Internet service provider; pages that you visit before and after using the Services, browsing history, and search history; the date and time of your visit; information about the links you click, pages you view, and advertising you interact with within the Services and other information about how you use the Services; the technology on the devices you use to access these Services. If you or your device experiences an error, we may collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred.

2. SOURCES OF PERSONAL INFORMATION

In addition to personal information we receive from you, we may also receive the categories of personal information described above from other sources, including from other users of our Services, our family of companies and related entities, affiliates, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, and social networks. For example, we may receive your personal information from our affiliates when you participate in sweepstakes, contests, and similar promotions. As another example, if you connect your social media account to accounts you create with our Services, we may collect personal information from these third-party organizations.

3. COOKIES AND OTHER TECHNOLOGIES

Using cookies. Cookies are pieces of information stored directly on the computer or device that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our partners use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Services, as well as for online tracking purposes.

If you do not want information collected through the use of cookies, there is a procedure in most browser settings that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.

For full details on how we use cookies and other technologies, please visit our Cookies Policy.

Using pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.

4. HOW WE PROCESS PERSONAL INFORMATION

We may use the personal information we collect for the purposes set out below, as applicable:

• To perform the Services, including to process or fulfill a contract, including orders and transactions, to provide analytic services, to fulfill requests for products and services, to maintain or service accounts, to verify customer information, and to provide you with customer service.
• For our legitimate business purposes or with your consent, as applicable, including:
  • To market and advertise the Services, including by processing your personal information for targeted advertising both on and off the Services;
  • To improve the Services, including to undertake internal research for analytics;
  • To help keep the Services effective and secure;
  • To contact you, including to send information to you in response to your requests;
  • For any other purpose disclosed to you at the time we collect your personal information with your consent.
• To comply with applicable laws and regulatory obligations.

5. HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose the personal information we collect to the following categories of third parties:

• Our Family of Companies and related entities
• Service providers and business partners
• With your consent
• In connection with a commercial transfer
• For legal purposes

6. DATA SECURITY

We use reasonable organizational, technical and administrative measures to protect personal information within our organization. You should understand that no data transmission or storage system can be guaranteed to be 100% secure. Please note that personal information collected by third parties may not have the same security protections as personal information you submit to us, and we are not responsible for protecting the security of such personal information.

7. DATA RETENTION

We will retain the personal information we collect only for so long as reasonably necessary for the purposes and criteria outlined in this Privacy Policy. When determining retention of personal information we take into account the length of time personal information is required to be retained to provide the services; to satisfy legal and compliance obligations and for audit purposes; to address any complaints regarding the services; to address any relevant litigation or regulatory investigations; and to defend or bring potential legal claims.

8. MINOR INFORMATION

We do not knowingly collect personal information from individuals under 21 years old. We do not knowingly sell or share for cross-context behavioral advertising the personal information of individuals under 21 years old.

9. YOUR PRIVACY RIGHTS AND CHOICES

Depending on where you reside, you may have, in accordance with applicable law, the following rights:

1. Right to Know: You may have the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which it is collected, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it.
2. Right to Access & Data Portability: Subject to certain exceptions, you may have the right to request a copy of the personal information we collected about you.
3. Right to Correction and Deletion: You may have the right to request that we correct or delete your personal information in certain circumstances.
4. Right to Opt-Out: You may have the right to opt-out of the sale of your personal information and processing of personal information for targeted advertising.
5. Right to Withdraw Consent: Depending on where you reside, where our processing of your personal data is based on consent, you have the right to withdraw consent at any time.

10. ADDITIONAL INFORMATION FOR USERS OUTSIDE THE UNITED STATES

The Services are directed at users in the United States.

11. UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy at any time, so please review it frequently. Please take a look at the "Last Updated" date at the top of the Privacy Policy to see when it was last revised. Any changes will become effective at the "Last Updated" date. If we make a material change to this Privacy Policy, we will update the "Last Updated" date on this Privacy Policy.