Effective Date: May 24, 2020

Thanks for visiting Shugart Concepts! Shugart Concepts, LLC (“Shugart Concepts”, “we”, “us” or “our”) respects your privacy. When it comes to your personal information, we believe in transparency, not surprises. That’s why we’ve set out here what personal information we collect, what we do with it and your choices and rights.

By using any of Shugart Concepts, LLC’s Services, you confirm you have agreed to our Policies and read and understood this Privacy Policy.

1. Some key terms

In our Privacy Policy, when we refer to “Users”, we mean our customers who use our Services, including visitors to our site. We explain who we are in the “Who is Shugart Concepts?” section below.

2. How does this Privacy Policy apply?

This Privacy Policy describes what we do with personal information that we collect and use for our own purposes (i.e., where we are a controller), such as your account information and information about how you use and interact with our Services, including information you submit. We also describe what third parties we use that may have access to some or all of the information you provide to us and link to their Privacy Policies for your convenience in the "How we share your personal information" section below.

3. Personal information we collect

We collect various personal information regarding you or your device. This includes the following:

· Information you provide to create an Account, specifically email address, first name and last name. If you make a purchase on our site, we receive a portion of your payment information from our payment processor (such as the last four digits, the country of issuance and the expiration date of the payment card).

· Your marketing preferences.

· The emails and other communications that you send us or otherwise contribute, such as customer support inquiries.

· Information you share with us in connection with surveys, contests or promotions.

· Information from your use of the Services or our site. This includes: IP addresses, preferences, web pages you visited prior to coming to our or our site, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services and our Users’ sites (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).

· Information we get from our partners to support our marketing initiatives, improve our Services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.

· Other information you submit to us directly or through Third Party Services.

4. How we collect personal information

We obtain personal information from various sources. We do this in three main ways:

· You provide some of it directly (such as by registering for an Account or making a purchase).

· We record some of it automatically when you use our Services or Users’ sites (including with technologies like cookies).

· We receive some of it from third parties (like when you register for an account using a Third Party Service or when you make payments to us using our payment processor).

We’ve described this in more detail below.

a. Personal information you provide

When you use our Services, we collect information from you in a number of ways. For instance, we ask you to provide your name and email address to register and manage your Account. We also maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute, such as customer support inquiries. You might also provide us with information in other ways, including by responding to surveys, submitting a form or participating in contests or similar promotions.

Sometimes we require you to provide us with information for contractual or legal reasons. For example, we may ask you to select your jurisdiction when you make a purchase to determine if, and how much, tax we need to collect from you. We’ll normally let you know when information is required, and the consequences of failing to provide it. If you do not provide personal information when requested, you may not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it.

b. Personal information obtained from your use of our Services

We use Squarespace, Inc to host our site and to provide customers with our Services. When you use our Services, Squarespace, Inc collects and uses some information. View Squarespace's privacy policy for more information about how they use and collect Users information.

If you are an End User of our Users’ sites, we also get information about your interactions with their sites, though we use this in anonymous, aggregated or pseudonymized form which does not focus on you individually. We use this data to evaluate, provide, protect or improve our Services (including by developing new products and services).

Some of this information is collected automatically using cookies and similar technologies when you use our Services and our site. You can read more about Squarespace's use of cookies in their Cookie Policy. Some of this information is similarly collected automatically through your browser or from your device.

c. Personal information obtained from other sources

If you use a Third Party Service (such as Google) to register for an Account, the Third Party Service may provide us with your Third Party Service account information on your behalf, such as your name and email address (we don’t store passwords you use to access Third Party Services). Your privacy settings on the Third Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third Party Service.

If you sign up for Paid Services, we obtain limited information about your payment card from our payment processor, such as the last four digits, the country of issuance and the expiration date. Currently, our payment processor is Stripe. Stripe uses and processes your complete payment information in accordance with Stripe’s privacy policy.

5. How we use your personal information

We use the personal information we obtain about you to:

· Provision of the Services. Create and manage your Account, provide and personalize our Services, process payments and respond to your inquiries.

· Communicating with you. Communicate with you, including by sending you emails about your transactions and Service-related announcements.

· Surveys and contests. Administer surveys, contests and other promotions.

· Promotion. Promote our Services and send you tailored marketing communications about products, services, offers, programs and promotions of Shugart Concepts and measure the success of those campaigns. For example, we may send different marketing communications to you based on your previous purchases or what we think may interest you based on other information we hold about you.

· Advertising. Analyze your interactions with our Services so we can tailor our advertising to what we think will interest you. For example we may choose to serve you a particular advertisement based on your previous purchase(s) or what we think may interest you based on other information we hold about you.

· Customizing the Services. Provide you with customized services. For example, we use your location information to determine your language preferences or display accurate date and time information. We also use cookies and similar technologies for this purpose.

· Improving our Services. Analyze and learn about how the Services are accessed and used, evaluate and improve our Services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually. For example, if we learn that most use a particular integration or feature, we might wish to expand on that integration or feature.

· Third party relationships. Manage our vendor and partner relationships.

· Enforcement. Enforce our Terms of Service and other legal terms and policies.

· Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.

We process your personal information for the above purposes when:

· Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.

· Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so you can sign in to your account.

· Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.

· Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:

o To operate the Shugart Concepts business and provide you with tailored advertising and communications to develop and promote our business.

o To provide and improve the Services, including any personalized services - we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis.

o To share your personal information with other companies that help us provide and improve the Services.

· Others’ legitimate interests. Where necessary for the purposes of a third party’s legitimate interests, such as our partners who have a legitimate interest in delivering tailored advertising to you and monitoring and measuring its effectiveness.

6. How we share your personal information

We share personal information in the following ways:

· Affiliates. We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the services we or they provide.

· Business partners. We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their Third Party Services, but only when you have been informed or would otherwise expect such sharing.

· Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage.

· Process payments. We transmit your personal information via an encrypted connection to our payment processor.

· Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests or prevent fraud. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.

· Advertising. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness.

· Business transfers. If we're involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal.

We share or use all or some information with the following third parties as necessary to provide you with Services and to complete contractual obligations.

· Website host Squarespace, Inc

· Payment Processors, Stripe, Inc, Intuit, Inc. and Paypal, Inc

· Shipping Service Providers, Shipstation and USPS, as well as other shipping providers as needed

· Marketing Service Providers, Mailchimp and others as needed

7. Your rights and choices

Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.

You can access, update, change or delete personal information (or that of your End Users) either directly in your Account (if applicable) or by contacting us at shugartconcepts@gmail.com to request the required changes.

You can also elect not to receive marketing communications by changing your preferences in your Account or by following the unsubscribe instruction in such communications.

Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.

You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. If you are subject to EU data protection laws, we suggest you lodge any such complaints with the Information Commissioners Office (ICO) in the UK.

Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

Squarespace's (our website host) Cookie Policy explains how you can m anage cookies and similar technologies.

8. How we retain your personal information

We retain personal information regarding you or your use of the Services for as long as your Account is active or for as long as needed to provide you or our Users with the Services. We also retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements and to protect our and others’ interests.

The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the period we keep your email address is connected to how long your Account is active, while the period for which we keep transaction history is connected to United States law.

You may delete your information by contacting us at shugartconcepts@gmail.com and Shugart Concepts will delete the personal information it holds about you (unless we need to retain it for the purposes set out in this Privacy Policy).

Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.

9. Data transfers

Personal information that you submit through the Services may be transferred to countries other than where you live, such as, for example, to our servers in the U.S. We also store personal information locally on the devices you use to access the Services.

Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.

We rely upon a number of means to transfer personal information which is subject to the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR. These include:

· Standard data protection clauses. We may, in accordance with Article 46 of the GDPR, transfer personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area.

· Other means. We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding enforcement commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules.

10. Updates to this Privacy Policy

We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy and post it on our site. If we make material changes to it or the ways we process personal information, we’ll notify you (by, for example, prominently posting a notice of the changes on our sites before they take effect or directly sending you a notification).

We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit. This will help ensure you better understand your relationship with us, including the ways we process your personal information.

11. Who is Shugart Concepts?

When we say “Shugart Concepts” (or “we”, “us” or “our”), we mean: Shugart Concepts, LLC.

12. How to contact us

If you have questions, comments or complaints about this Privacy Policy or our privacy practices or if you would like to exercise your rights and choices, please email us at shugartconcepts@gmail.com, or write to us at the address below:

Shugart Concepts, LLC

11310 W. Carr Ct.

Wichita, KS 67209, USA