SGC Privacy Notice

Your privacy is important to us at New SGC LLC, (“SGC”, “we”, “our” or “us”). This SGC Customer Privacy Notice (“Privacy Notice”) describes the practices of SGC with respect to the personal information we collect in connection with this website, gosgc.com (the “Website”), any other web or mobile application we operate, or from any other interaction with SGC (such as emails, newsletters, or forms) where we display or link to this Privacy Notice (collectively with the Website, the “Services”).

Please carefully read this Privacy Notice, which is part of and subject to our Terms & Conditions, before using our Website or Services, including, without limitation, gosgc.com, and any related SGC web pages that display this Privacy Policy.

By accessing or using our Website or Services, you consent to the terms of this Privacy Notice.

California residents. Please see the state-specific disclosures, including applicable “Notice at Collection disclosures, in Section IX, “Additional Disclosures for Residents of Certain U.S. States,” below.

Users With Disabilities and ADA compliance. If you are an individual with a disability or assisting a user with a disability, and have difficulty accessing or navigating our digital channels – including this Privacy Notice – please contact us at support@gosgc.com.

I.   Information We Collect. We collect personal information that varies depending on how you use the Services or otherwise interact with us.

Personal Information You Provide to Us. We collect Personal Information you give us when you use certain Services, including:

• Information you provide to us during account creation, including identity data such as your full name;
• Contact Information and Account Information you provide to us during order submission, such as mailing address, billing address, email address, phone number, username and password, preferences, feedback and survey responses;

For example, we may ask for your name, email address and account name when you sign up for an account with us, and we may ask for a street address, or phone number when you submit an order. We also may collect information about the cards you’ve added to orders, how frequently you submit orders, and your use of promo codes.

Personal Information Shared with Us from Third-Parties. You consent to sharing some of your personal information with certain types of third parties for the purpose of using our Services when agreeing to our Terms & Conditions, including:

• Information we collect from third-party shipping carriers and payment processors;

For example, a payment provider may return an email address or phone number that you provided to your bank, and a shipping carrier may return a zip code with your postal code. This information is logged as part of your transaction but not added to your customer profile.

Please note we are not responsible for the policies and practices of third parties. Any information you give to those organizations is dealt with under their privacy policy, the SGC Terms & Conditions, and other applicable policies.

Personal Information Collected Automatically. In addition, we may use various tools and technologies like cookies and web server logs to automatically collect information about your use of the Services, including:

• Device information - such as your hardware model, IP address, other unique device identifiers, operating system details, web browser type and version, internet service provider details, referring URLs, time and length of visits, and pages viewed, and settings of the device you use to access the Services.
• Usage information - the time and duration of your use of the Services and other information about your interaction with content offered through a Service, and any information stored in cookies and similar technologies that we have set on your device.
• Location information - such as your device’s IP address, your mobile device’s rough GPS signal when you use the Services.
• Geolocation Information, which may include your IP address location; and
• Transaction, Technical, and Communication Information, as well as Marketing Preferences our IT systems collect about your use of our Services, such to improve and customize your experience using our Services

This type of information would be used for system and Service troubleshooting. This information is not linked directly with your account and the personal information you have provided us.

II.   How We Use Information. We process the personal information we collect for the following purposes:

• Register and create your account
• Send promotional, informational, and other communications relating to the SGC services you use
• Process and fulfill orders you submit
• Deliver products and services you requested or contracted for
• Charge payments and issue refunds for Services you request
• Provide and manage the Services you request
• Communicate with you about our products, services, and promotions
• Provide customer support and respond at your request
• Manage your API credentials and access to data
• Perform troubleshooting and debugging on IT systems
• To comply with, establish, assert, exercise, defend against, or enforce any legal claims, legal rights, legal obligations, legal process, government requests, SGC policies, internal investigations, or prudent security or business practices. This includes (but is not limited to) enforcing this Privacy Notice and any other contract(s) or agreement(s) we may have with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests
• Help improve, upgrade, or enhance our services and products and develop new services and products
• To monitor and detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, and hold those responsible for that activity
• Enforce our Terms & Conditions, including in this Privacy Notice, and
• As permitted by law, or as you may otherwise direct or agree to in the course of using our products and services.

III.   Sharing of Your Personal Information

We may share your Personal Information to third parties for any purpose described above in Section II (“How We Use Information”), including without limitation as follows:

• For payment processors of our choosing to facilitate a payment or refund, including, but not limited to PayPal and Authorize.Net, to complete credit card, debit card, PayPal, or any other SGC pre-approved method of payment.
• Shipping carriers and shipping carrier software providers, including but not limited to, USPS and FedEx. If you visit one of these linked websites, you should read the website’s privacy policy, Terms and Conditions, and their other policies.
• Authentication platforms to verify your credentials.
• As you direct, or to fulfill the purpose for which you provide it, including any purpose disclosed at the time you provide the information.
• To SGC affiliated entities.
• Marketing and automation platforms for the purposes of sending notifications of events, products, and promotions that you have opted-in to.
• To designated service providers 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 comply with any court order, law or legal process, including to respond to any law enforcement, government or regulatory request.
• To protect the health, safety, welfare, rights, or interests of you, us, any third party, or the general public; or to protect the safety and integrity of our services, troubleshoot issues, and detect and prevent errors, fraudulent activity, or other potentially wrongful, harmful, or illegal activity. Such disclosures may include disclosures to other users, businesses, insurance companies, law enforcement, third-party owners, or others.
• To facilitate a corporate or business transaction such as a merger, acquisition, or sale of assets.
• To enforce or apply our Terms & Conditions and other agreements, including for billing and collection purposes.

IV.   Your Privacy Rights and Choices

You have options regarding our collection, use, and disclosure of your personal information. The precise choices available to you may depend on legal rights you have as a resident of certain jurisdictions, but generally include:

• Email Preferences. You can opt-out of receiving marketing emails or newsletters from us at any time by clicking the “Unsubscribe” link in any such email, or by emailing us as set forth below in the “Contact Us” section. Please note that even if you opt out, we may still send communications to you about your transactions, any accounts you have with us, any request or inquiry you have made, or other non-marketing related matters. Alternatively, you may opt-out by logging into your account at gosgc.com, selecting “My Profile,” and opting out of the emails.
• Personal Information Management and Preferences.You may access or modify your personal information and marketing preferences by the following methods:

  1. Logging into gosgc.com with your account and selecting “My Profile”, or

  2. Using the “Collector Support” or “I Need Help” links on to the gosgc.com and selecting the “General Inquiries” or any option specifically naming Personal Information from the Type of Inquiry dropdown.

Please note, that we currently do not allow you to edit your shipping addresses when they have been added to an order. You will receive a popup notification of this issue if you attempt to edit an address that meets this criteria in your profile.

Depending on the U.S. jurisdiction where you reside, you may exercise additional rights, detailed below in subsection F, “Your State Law Privacy Rights,” of Section IX, “Additional Disclosures for Residents of Certain U.S. States.”

V.   Data Security and Other Important Information

Data Security. SGC has procedural, technical and physical security measures to help protect against the risk of loss, misuse, and alteration of information that you provide, including Personal Information. We request third parties with whom we share Personal Information to do the same. Nevertheless, such security measures may not prevent all loss, misuse, or alteration of information on the Websites or Services, and SGC is not responsible for any damages or liabilities relating to any such security failures. By using the Websites or Services, you understand that there is a risk that data and communications, including email and other electronic communications, may be accessed by unauthorized third parties. The foregoing does not affect any liability that cannot be excluded or limited under applicable law.

Please do not provide your password to another person. We cannot be responsible for a data breach or other incident if you disclose your password to unauthorized persons.

VI.   Protecting Children’s Privacy. Our Website and Services are intended for use solely by persons 18 years of age or older. If you are under 18 years of age, please do not use our Website or Services, or provide your personal information to SGC.

VII.   Notice of Monitoring. We and our service providers and third-party partners may monitor any use of or activity on our sites and Services and may capture and retain records reflecting your activity on our sites and Services for our business purposes. This may include records reflecting actions you take while using our sites and Services (such as clicks on pages or links, items viewed, scrolling, time spent on pages, and other activities), records of parts or all of your sessions on our sites or Services, information you submit on or via our sites or Services, or communications or information sent through or using our sites or Services. The cookies and similar tracking technologies described in this Privacy Notice may also collect the foregoing information reflecting your use of and activity on our sites and Services, or may enable our third-party partners to collect such information. This information may be collected, retained, captured, and/or monitored by us or by our service providers and third-party partners. If you do not consent to the monitoring described here, you should not use our sites or Services.

VIII.   Links to Other Sites. Third Party Websites and Services. Our Website or Services may include links to websites or other online properties that are not under our control. Our website may link to our shipping carriers, social media accounts, and job posting on third-party websites, including, but not limited to FedEx, USPS, PayPal, Facebook, Instagram, Twitter, LinkedIn, Indeed, and services that we do not operate and are outside of our control. SGC shall have no responsibility or liability for the content or privacy practices of any such linked website or any link or linking program at any time. Please exercise caution and review the privacy statements applicable to the third-party websites and services you use. If you click on a link on our Website and link to a third party’s website, then this Privacy NoticePrivacy Policy will not apply to your Personal Information collected on that third party’s website and you must read the privacy policy on that website to see how your information will be handled. Social media widgets or tools may appear on our Websites or Services. Your interaction with and use of these widgets or tools will be governed by the terms of use and privacy policy of the applicable social media provider (e.g., Facebook).

IX. Additional Disclosures for Residents of Certain U.S. States

A. Categories of Personal Information We Collect

1.   Identifiers as well as identifying information described in Cal. Civ. Code § 1798.80(e), such as name; social security, driver’s license, and passport number; email and mailing address; phone number; account name and other online identifiers; credit and debit card numbers; and billing information;

2.   Commercial information, including products and services you purchased, obtained, or considered;

3.   Audio, electronic, visual, or similar information, such as records of images of you provide to us or our Services;

4.   Characteristics of protected classifications under California or federal law, such as demographic information including age and gender.

5.   Sensitive Personal Information, such as account login credentials and payment card-related information;

6.   Professional or employment-related information, such as information provided by our dealers partners about their businesses and employees;

7.   Internet or other electronic network activity information, such as browsing history and information regarding your interaction with our Services;

8.   Inferences drawn from the information listed above.

B.   Sources of Information. We collect the above categories of Personal Information directly from you or your device, from your interactions with our Services, from publicly available sources, and from third parties. For more information, see “Information We Collect,” above.

C.   Business or Commercial Purposes for Collection. The above section titled “How We Use Information” describes the business and commercial purposes for which we collect personal information.

D.   Retention of Personal Information. We retain Personal Information for the period(s) necessary to perform the purposes outlined in this Notice, unless applicable law permits or requires a longer period. Please note that this means that we may be required to retain Personal Information after the end of our direct relationship with you.

E.   Disclosures of Personal Information; Targeted Advertising. The above section titled “How We Share Information” describes the categories of third parties to whom we disclose personal information for the following purposes:

• Disclosures for business purposes. We disclose all or substantially all of the above-listed categories of personal information with all categories of third parties identified in this Privacy Notice for our business purposes.
• Sales/Sharing and Targeted Advertising. We do not sell your data for monetary consideration. However, like many companies that operate online, SGC sites may host third-party information-collecting tools (e.g., cookies, pixels, beacons, etc.) that leverage your browsing data for targeted advertising. Under certain state laws this may result in us “sharing” your data for “targeted advertising,” from which you have the right to opt out. We may share identifiers, internet and other electronic activity information, and inferences with ad networks, social media providers, or advertising providers for this purpose. We do not knowingly sell or share personal information of individuals under 18 years of age for targeted advertising. To opt-out of the sharing of your data for targeted advertising, see the “Your State Law Privacy Rights” section immediately below.

F.   Your State Law Privacy Rights. If you are a resident of California, Texas, or Virginia, you can request to exercise the following rights:

• The Right to Access / Know. You may confirm whether we process your Personal Information and request access to the specific pieces of personal information we maintain about you.
• The Right to Correct. You have the right to correct any Personal Information we maintain about you that is inaccurate.
• The Right to Delete. You have the right to request that we delete the Personal Information we have collected from you. Please note that exercising this right may affect our ability to provide you Services that require us to have certain Personal Information about you.
• Opt-Out of Sharing for Targeted Advertising. To opt-out of offline sharing for targeted advertising, you can submit a request to Opt-Out by emailing privacy@gosgc.com. Note: We do not currently engage in offline sharing for targeted advertising, but your opt-out will be honored if in the future we do so.

Some state laws may grant you a right to appeal a denial of your rights request. If this is applicable to you, our response to your request will provide details on how to submit an appeal.

We do not process sensitive personal information in a way that requires us to provide a “Right to Limit” use or disclosure of sensitive information. As required by applicable law, we will not discriminate against you because of your exercise of any of the above rights.

G.   How to Exercise Your Rights. To exercise a right applicable to you, you may employ one of the following methods:

• Logging into gosgc.com with your account and selecting “My Profile”, and selecting “Request Deletion of my Account” from the Type of Inquiry dropdown,
• Logging into gosgc.com with your account and selecting “I Need Help”, and selecting “Request Deletion of my Account” from the Type of Inquiry dropdown, and
• Emailing privacy@gosgc.com

Whichever way you elect to contact us, we may take steps to verify your identity before fulfilling your privacy rights request. We may require you to provide your name, contact information, and other information necessary to help verify your identity. If we cannot verify your identity, we may deny your request.

Please note that SGC does not allow users to request deletion of their personal data and keep their existing account active. Once you submit a deletion request, your account will be placed on hold. You will not be able to submit orders during this time. You will still be able to log into your account, access all your orders and personal information, and submit support requests.

Please also note that there are some reasons we will not be able to fully address your request, including, but not limited to, if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to reconcile any payment or carrier shipping disputes, to exercise our rights, for our internal purposes, or to comply with a legal obligation.

X.   Changes to This Privacy Notice. We may modify this Privacy Notice from time to time. Such changes will be posted to this page. We will notify you of material changes by appropriate means. Any changes to the Privacy Notice will become effective and will supersede all previous terms as of the Effective Date. Your use of the Services following such a change indicates your acceptance of the revised Privacy Notice.

XI.   Contact Us: If you have any questions about the content or subject matter of this Privacy Notice, please contact us by:

• Emailing us at privacy@gosgc.com
• Logging into gosgc.com with your account and selecting “I Need Help”

Effective Date: December 30, 2024