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Privacy Policy

Last Updated: 05/27/2026

Your privacy is very important to us and we take your privacy very seriously. This Privacy Policy describes how Merchant Industry, LLC dba Suede (“Company”, “we”, “us”, or “our”) collects and uses the personal information you provide to us on our website and all other websites, mobile sites, applications, platforms and tools where this Privacy Policy appears or is linked, and through the use of our services, (collectively the “Site”). It also describes the choices available to you regarding our use of your personal information and how you can access and
update this information.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and we are responsible as “controller” of that personal information for the purposes of those laws.

By creating an account, providing information to us (by any means, whether in correspondence, via our Site, or otherwise), or continuing to use our services, you acknowledge that you have read, understood, and consent to be bound by this Privacy Policy.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR OUR PRACTICES, YOU MAY NOT USE OUR SITE. THIS PRIVACY POLICY MAY CHANGE FROM TIME TO TIME AND YOUR CONTINUED USE OF OUR SITE CONSTITUTES YOUR ACCEPTANCE OF THOSE CHANGES. WE ENCOURAGE YOU TO REVIEW THIS PRIVACY POLICY PERIODICALLY.

1. Personal Information We Collect About You

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

Categories of Personal Information Examples Personal Information
*Note, this does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us
Collected
Category A - IdentifiersA real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.Yes
Category B - Customer records information (i.e. Information that identifies, relates to, describes, or is capable of being associated with, a particular individual) Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

*Some personal information included in this category may overlap with other categories.
Yes
Category C - Characteristics of protected classifications under state or federal lawAge (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).No
Category D - Commercial informationRecords of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Yes
Category E - Biometric informationRetina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry.No
Category F - Internet or other electronic network activity informationBrowsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.Yes
Category G - Geolocation dataPhysical location or movements.No
Category H - Sensory dataAudio, electronic, visual, thermal, olfactory, or similar information.No
Category I - Professional or employment-related information.Place of employment, position, job history, salary, resume, and other related data.Yes, if you apply to work with us
Category J - Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.No
Category K - Sensitive personal information (1) personal information that reveals:

A person’s social security, driver’s license, state identification card, or passport number;

A person’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;

A person’s precise geolocation;

A person’s racial or ethnic origin, religious or philosophical beliefs, or union membership;

The contents of a person’s mail, email, and text messages unless the business is the intended recipient of the communication; or

A person’s genetic data.

(2) the processing of biometric information for the purpose of uniquely identifying a consumer;

(3) personal information collected and analyzed concerning a consumer’s health, or a personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
No
Category L - Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.An inference is essentially a characteristic deduced about a consumer (such as ‘married,’ ‘homeowner,’ ‘online shopper,’ or ‘likely voter’) that is based on other information a business has collected.No

This personal information may be required to provide our Site or products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.

2. Cookies and Other Tracking Technologies

Cookies

Cookies are small text files of information stored by the Internet browser on your computer’s hard drive. We may use these cookies to collect browsing data to keep track of your preferences and profile information and to collect general usage and volume statistical information. Our cookies do not collect personal or confidential information and are not spyware.

There are a number of different types of cookies, however, our Site uses:

Essential – These cookies are necessary to the core functionality of our Site and some of its features, such as access to secure areas.

Performance and Functionality – These cookies are used to enhance the performance and functionality of our Site. For example, we may use these cookies so that we recognize you on our Site and remember your previously selected preferences. These could include what language you prefer and your geographic location. These cookies are nonessential to the use of our Site, however, without these cookies, certain functionality may become unavailable. A mix of first-party and third-party cookies are used.

Analytics and Customization –Our Company uses these cookies and technologies to analyze how the Site is accessed, used, or performing in order to improve your user experience and to maintain, operate and continually improve the Site. For example, we use Google Analytics on the Site to collect: page url/page title and user browser/system information, which includes browser type, referrer, language, java/flash support, IP address, and ad-serving data. For information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, visit Google’s “How you can control the information collected by Google on these sites and apps” article available here.

Advertising – These cookies are used to make advertising messages more relevant to you, prevent the same ad from continuously reappearing, ensure that ads are properly displayed for advertisers, and (in some cases) select advertisements that are based on
your interests. Our Company sometimes shares online data collected through these cookies with our advertising partners. If you would like to learn more about the third party advertisers that may be aware of the fact that you visit the Site, and to understand your choices about having such advertisers’ cookies turned off, please visit http://www.aboutads.info/choices/, http://www.youronlinechoices.com/, or
http://www.networkadvertising.org/

Unclassified – These are cookies that have not yet been categorized. We are in the process of classifying these cookies with the help of their providers.

Web Beacons

Our Site contains electronic images known as web beacons (sometimes called single-pixel gifs, clear gifs, and web bugs). Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Site users. In contrast to cookies, which are stored on an individual’s computer hard drive, web beacons are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We use web beacons along with cookies to compile aggregated statistics to analyze how our Site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns. We use a third party to gather information about how you and others use our Site. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated
information to understand and optimize how our Site is used.

How to Manage Cookies

You have the right to decide whether to accept or reject certain cookies. You can set your browser not to accept cookies, and the above websites tells you how to remove cookies from your browser. However, in a few cases, some of our Site features may not function as a result. Essential cookies cannot be rejected, as they are strictly necessary to provide you with our Site.

3. Do Not Track and Global Privacy Control

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or Global Privacy Control (“GPC”) signal setting you can activate to signal your privacy preferences. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signal.

We are, however, working to recognize Global Privacy Controls communicating your opt out preferences on the Site. 

We are also committed to providing you with meaningful choices about the information on our Site for third party purposes and that is why we also provide the variety of other opt-out mechanisms described in this Policy.

4. Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone or post- including through the possible use of automated technology and recorded messages) about our Site, your account, your service or transaction updates, our products and/or services, including exclusive offers, promotions or new products and/or services, and for appointment reminders or scheduling notifications. Messaging frequency varies. Receiving text messages from us is free of charge. However, standard text messaging rates
from your wireless carrier may still apply.

We have a legitimate interest in processing your personal information for promotional purposes (see below “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where
consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us by using one of the methods listed in the “How to Contact Us” Section below;
  • Using the “unsubscribe” link in emails or “STOP” number in texts.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further communications or products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business. If you opt-out of promotional communications, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

5. How Your Personal Information is Collected

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our Site and product applications. However, we may also collect information:

  • Directly from a third party (e.g., joint marketing partners, affiliate programs, data providers);
  • From a third party with your consent (e.g., your bank);
  • From cookies on our Site; and
  • Via our IT systems, including automated monitoring of our Site and other technical systems, such as our computer networks and connections, access control systems, communications systems, and email and instant messaging systems.

6. How and Why We Use Your Personal Information

Under data protection law, we can only use your personal information if we have a proper reason for doing so. We use personal information collected via our Site for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal and regulatory obligations. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

We use (process) your personal information:

  • To provide the Site and mange functionality, including for the purposes of managing your account and keeping it in working order;
  • To provide our products, and/or services to you;
  • To contact and communicate with Site visitors, including responding to requests and inquiries, providing customer service, confirming sub-missions;
  • To prevent and detect fraud against you or Company;
  • Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. rules issued by our professional regulator or if we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond;
  • Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies;
  • Ensuring business policies are adhered to, e.g. policies covering security and internet use, and to enforce our terms, conditions and other applicable policies;
  • Operational reasons, such as improving efficiency, improving the user experience, performance monitoring, training and quality control;
  • Ensuring the confidentiality of commercially sensitive information
  • Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures;
  • Updating and enhancing customer records;
  • Marketing our services to:
    • existing and former customers;
    • third parties who have previously expressed an interest in our services;
    • third parties with whom we have had no previous dealings.

We may also anonymize, aggregate or de-identify personal information so the end-product does not identify you or any other individual. Such aggregated, anonymized or de-identified information is not considered personal information for purposes of this Privacy Policy and we may use it for any purpose. For example, we may use this information to generate norms by industry, geography, level, etc., enable us to understand where our services are being utilized, conduct ongoing validation studies, compile reports, and improve the services.

7. Who We Share Your Personal Information With

We may share personal information with: 

  • Our affiliates, and subsidiaries. We may disclose your personal information to other entities within our family of brands to fulfill any purpose described in this Privacy Policy.
  • Our Service Providers. We disclose your personal information to third parties that provide business, professional, or technical support services to us and/or administer activities on our behalf.
  • Our Analytics Providers. We disclose your personal information to parties that assist us in performing analytics and help us measure the effectiveness of the Site and our marketing and advertising efforts.
  • Our Marketing and Advertising Partners. We disclose your personal information to our marketing and advertising partners, including social media networks, third-party advertising networks, and other parties that assist us in serving, measuring the
  • performance of, and optimizing our advertisements.
  • Governmental and Public Authorities. We disclose your personal information to government and public authorities as necessary or permitted by the laws of any jurisdiction in which we operate, including in response to a subpoena, court order, investigative demand, request for cooperation from a law enforcement agency, or similar request from a self-regulatory body or government agency.
  • Relevant Third Parties in Connection with a Business Transaction. We may disclose or otherwise transfer your personal information to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction as well as in the event of any insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. 

We may also need to share some personal information with other parties to the extent we believe it is necessary or appropriate to (1) protect our operations and those of our affiliates and subsidiaries; (2) investigate and prevent against fraud and other illegal activity; (3) protect our rights, privacy, safety, property, and/or those of others; or (4) allow us to pursue available remedies or limit damages that we may sustain. 

We may disclose your personal information for other reasons described at the time of information collection or prior to disclosing your information. Additionally, we may disclose your personal information with your consent or when you direct us to do so. 

Except as set forth above, we will not share your personal information with any other third party.

8. How Long Your Personal Information Will Be Kept

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements, to respond to any questions, complaints
or claims made by you or on your behalf, and to show that we treated you fairly). 

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of personal information; the potential risk from unauthorized use or disclosure of the personal information; the purpose(s) for which we use or may use the personal information; whether we can achieve the purpose(s) through other means; and the applicable legal requirements.

9. Children and Our Site

Our Site is not directed to children, and you may not use our Site if you are under the age of 18. If you are under 18, do not use our services, access the Site, or provide any information about yourself including, without limitation, your name, address, email address or any screen
name or user name you may use. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, in compliance with the Children’s Online Privacy Protection Act, we will purge such information from our database and cancel the corresponding accounts. If you believe we may have any information from or about a child under 13, please see our “How to Contact Us” Section below. Please visit the FTC’s website at www.ftc.gov for tips on protecting children’s privacy online.

10. Keeping Your Personal Information Secure

We use reasonable and appropriate physical, technical, and administrative safeguards to protect your information from unauthorized use, access, loss, misuse, alteration, or destruction. We endeavor to protect the personal information we receive, gather and store, by such means as password protection, firewalls and other means. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also require that third party service providers acting on our behalf or with whom we share your information also provide appropriate security measures in accordance with industry standards. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Please note, however, no system can be completely secure and transmissions over the internet are never entirely secure. Therefore, although we take steps to secure your information, we cannot guarantee your information, searches, or other communications will always remain secure. Any such transmission of information by you over the internet is at your own risk.

11. A Note to Users Outside of the United States

Company is headquartered in the United States of America (“United States”) and utilizes third party agencies, service providers, representatives and agents as indicated above. The Site is not intended for Site visitors outside the United States. If you are a non-U.S. user of
the Site, by visiting the Site and providing us with data, you acknowledge and agree that your personal information may be processed for the purposes identified in this Privacy Policy. If you choose to access our Site outside the United States, Company and our third party agencies, service providers, representatives and agents may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. In particular, you are advised that the United States uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Where the laws of your country allow you to do so, by using the Site or the services or by providing your data, you consent and authorize Company to transfer, store, and use all such personal information in the United States (and any other country where we operate) which may not offer an equivalent level of protection to that required in the country where you reside and to the processing of that personal information by us on our servers located in the United States, as described in this Privacy Policy. If you do not want your personal information transferred to the United States and any other country
where we operate, please do not submit any information to us or use our Site or the services.

12. Your Rights and Choices

If you reside in the State of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia please go to our Privacy Notice Addendum to learn about additional rights you may have under applicable data protection laws.

13. Third Party Websites

If, in your interactions with the Site, you are linked or directed to, or click on, a third party website, we cannot control what information you may provide to that party or on that website, and we are not responsible for how that party may use or disclose any information you may provide to them. This is not as an endorsement by us of any third party website, content that may be offered on such third party website, or of any products or services provided by such third party. We do not control, nor are we responsible for, such third party website, product or service offerings. As such, we urge that you exercise caution before providing them with your personal information and to review the third party’s privacy policy for information on its data processing practice.

You should contact the site administrator for such third party website if you have any complaints, claims, concerns or questions regarding such third party website or its privacy practices.

14. Changes to this Privacy Policy

This Privacy Policy was published on the date “Last Updated” above.

We may change this Privacy Policy from time to time. Changes to this Privacy Policy will be made by updating this page. Please visit this Privacy Policy regularly to read the current version.

15. How to Contact Us

Please contact us by email if you have any questions about this Privacy Policy or the information we hold about you: Privacy@gosuede.com.

Privacy Notice Addendum

This Privacy Notice Addendum (“Notice”) supplements the information contained in the above Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota,
Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, (“consumers” or “you”).

We adopt this Notice to comply with the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), General Data Protection Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), the UK version of the GDPR, the California Shine the Lights law, the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), the Colorado Privacy Act, the Connecticut Data Privacy Act, the Delaware Personal Data Privacy Act, the Indiana Consumer Data Protection Act, the Iowa Consumer Data Protection Act, the Kentucky Consumer Data Protection, the Maryland Online Data Privacy Act, the Minnesota Consumer Data Privacy Act, the Montana Consumer Data Privacy Act, Nebraska
Data Privacy Act, New Hampshire Senate Bill 255, New Jersey Senate Bill 332, the Oregon Consumer Privacy Act, the Rhode Island Data Transparency and Privacy Protection Act, the Tennessee Information Protection Act, the Texas Data Privacy and Security Act, the Utah
Consumer Privacy Act, the Virginia Consumer Data Protection Act, and certain other privacy and data protection laws, as applicable (collectively, the “Statutes”). Any terms defined in the Statutes will have the same meaning when used in this Notice. Any terms used in this Notice but undefined herein shall have the meaning provided in the Privacy Policy.

As further set forth in our Privacy Policy, we may collect certain information that is (i) linked or reasonably linkable to an identified or identifiable individual or natural person, or (ii) that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household, or (iii) as further defined in the Statutes as “Personal Data” or “Personal Information,” as further described in our Privacy Policy.

1. Shine the Light Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law permits individuals who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. We do not disclose personal information that corresponds to the categories of personal information set forth under Cal. Civ. Code § 1798.83 to third parties for the third parties’ direct marketing purposes.

2. Personal Information We Sold or Disclosed for a Business Purpose

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

  • Category A – Identifiers
  • Category B – Customer records information
  • Category D – Commercial information
  • Category F – Internet or other electronic network activity information
  • Category I – Professional or employment-related information

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

  • Category A – Identifiers 
  • Category B – Customer records information 
  • Category D – Commercial information
  • Category F – Internet or other electronic network activity information 
  • Category I – Professional or employment-related information

3. Your Rights Under the CCPA

You may have the right under the California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

RightExplanation
Disclosure of Personal Information We Collect About YouYou have the right to know:
  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share personal information, if any; and
  • The specific pieces of personal information we have collected about you.
Please note that we are not required to:
  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold, Shared, Disclosed, or Used for a Business PurposeIn connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
  • The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
  • The categories of personal information that we disclosed about you for a business purpose.
You have the right under the CCPA and CPRA and certain other privacy and data protection laws, as applicable, to opt-out of the sale or sharing for cross-contextual behavioral advertising of your personal information. If you exercise your right to opt out of the sale or sharing for cross-contextual behavioral advertising of your personal information, we will refrain from selling or sharing for cross-contextual behavioral advertising your personal information, unless you subsequently provide express authorization for the sale or sharing for cross contextual behavioral advertising of your personal information.

We do use third parties to process your personal information on our behalf in accordance with our Privacy Policy, however, we do not share your personal information to these third parties for any cross-contextual behavioral advertising and we will continue to review our contracts with these third parties to ensure they are not permitted to sell or share your personal information
Right to Limit Use and Disclosure of Sensitive Personal Information.You have the right to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying requested goods or services. We do not collect sensitive personal information.
Right to CorrectionYou have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Right to DeletionSubject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against DiscriminationYou have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

4. Your Rights Under Other State Privacy Laws

Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, also provide consumers who are residents of these states with certain rights regarding their Personal Data. This section describes the rights you may have under these state privacy laws, under certain circumstances and subject to certain exceptions. Please contacts us if you have any questions about your rights under these state privacy laws.

Consumer RightExplanationApplies to Residents of
The Right to Opt OutYou may have the right to opt out of the processing of Personal Data concerning you for the purposes of:
  • Targeted Advertising;
  • The Sale of Personal Data; or
  • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia
The Right of AccessYou may have the right to confirm whether we are processing Personal Data concerning you and to access your Personal Data.

Please note, there may be restrictions on how often you may exercise this right.
Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia
The Right to CorrectionYou may have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.Colorado, Connecticut, Delaware, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Virginia
The Right to DeletionYou may have the right to delete Personal Data concerning you or to request that we delete Personal Data provided by, or obtained about, you.Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia
The Right to Data PortabilityYou may have the right to obtain a copy of your Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

Please note, there may be restrictions on how often you may exercise this right.
Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia
The Right to AppealWe hope that we can resolve any query or concern you raise about our use of your Personal Data. However, if we do not take action on your request to exercise any of your rights, we will inform you without undue delay after the receipt of the request our reason for not taking action. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Virginia

5. How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Notice, please:

Email us at Privacy@gosuede.com.

Please note that you may be restricted on the number of data access or data portability requests you may make within a 12-month period.

If you choose to contact us, we will take steps to verify your identity before granting you access to your personal information or complying with your request. In order to help protect your privacy and maintain security, you will need to provide us with:

  • Enough information to identify you (e.g., your full name, address, email address, telephone number, birth date, or customer or matter reference number); 
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.

In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

You may use a representative, called an “authorized agent,” to submit a request to us. 

In some states, an authorized agent must be a natural person, or a business entity registered with the appropriate Secretary of State, that you have authorized to act on your behalf. 

In order to protect your privacy, Company requires you to confirm that you have provided the authorized agent permission to submit the request and you must provide the authorized agent with signed permission. “Signed” means that the written attestation, declaration, or permission has either been physically signed or provided electronically pursuant to the Uniform Electronic Transactions Act. In California, an authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but in such cases, consumer verification will not be required.

Company may deny a request from an authorized agent that does not submit proof that they have been authorized to act on your behalf. Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described above.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. 

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

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