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PRIVACY NOTICE

Last Updated: January 18, 2024

Introduction:

This Privacy Notice for The Sutphen Corporation (“Company”, “we”, “us”, or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

Visit our website at https://www.sutphen.com/, or any website of ours that links to this Privacy Notice
Engage with us in other related ways, including any sales, marketing, or events.

By using our Services, you consent to our Privacy Policy and our collection, use, and sharing of your information in accordance with the terms below.

This Privacy Policy covers the following topics:

What types of information we collect
How we share the information we collect
Cookie policy
Third party links
How long we retain your information
How we store and protect your information
Policy on collection of information from minors
Your rights with respect to your information
Customers located in Europe and the UK
Do not track policy
Updates to this notice:
Contact information

What types of information we collect:

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include information that identifies you, such as:

names
phone numbers
email addresses
mailing addresses

Personal Information Provided Automatically. Some information may be obtained automatically when you use our website and Services. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. This information does not reveal your specific identity (like your name or contact information) but may include:

device and usage information
IP address
browser and device characteristics
operating system
language preferences
referring URLs
location
information about how and when you use our Services
and other technical information.

We may also use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in the section entitled “Cookie Policy”.

How we use the information we collect:

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To respond to user inquiries or other messages or requests from you
To communicate with you
To provide you with the Services or other products, features, or functions related thereto
To create and manage user accounts
To verify your identity
To personalize your experience using the Services
To provide you with information about us, our Services, and promotional offers
To improve our products and services
To offer technical support to you
To determine the effectiveness of our marketing and promotional campaigns
To comply with our legal obligations
To protect an individual’s health, safety, or welfare
For any other legal purpose with your consent

How we share the information we collect:

We will limit sharing of your personal information to the purposes and parties set forth in this Privacy Policy. Please be aware, however, that we may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates. We may share your information with other entities within the Company, including our affiliates, parent companies, or subsidiaries.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

As Required by Law. We may be required to share information in response to a court order, subpoena, search warrant, or to otherwise comply with a law or regulation.

Cookie Policy:

What are cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies may gather certain types of information from you, including demographic data, technical information, IP address, and information about your browsing activity.

How do we use cookies? We use different types of cookies for different purposes.

“Essential” cookies are necessary for us to provide the Services through the website and to enable you to use some features. If essential cookies are disabled, our website and Services may not work properly.
“Functionality” cookies store information such as choices you make and login information to provide you with a more personalized and efficient experience when using our website and Services.
“Analytics and Performance” cookies store information about traffic to the website and browsing behaviors so that we can ensure that our website is functioning as intended, to improve performance of the website and Services, and to ensure that linking and advertising are working properly.

We may also use third-party cookies to enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that provide these third party cookies can recognize your computer or device both when it visits the website in question and also when it visits certain other websites. We do not control these third party cookies, we are not responsible for any decisions you make with respect to third party cookies, and your rights with respect to third party cookies are governed by the privacy policies of their respective third party providers.

Can I deactivate cookies? You have the right to decide whether to accept or reject cookies. If you choose to reject cookies, you may still use our website, though your access to some functionality and areas of our website may be restricted. You can set or amend your web browser controls to accept or refuse cookies. In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

Third party links:

If you choose to visit any third party websites via any links provide on our websites, you will be leaving our Services and this Privacy Policy will not apply to your use of any such websites or services. Rather, your privacy rights with respect to any third party websites and services will be governed by the privacy policies provided on those sites or through those third party services.

How long we retain your information:

We will only keep your personal information for as long as necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. When we no longer have an ongoing legitimate business need to process your personal information, we will either delete or anonymize such information.

How we store and protect your information:

We have implemented appropriate and reasonable technical and organizational security measures to protect the security of any personal information we process. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

While we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk, and you should only access the Services within a secure environment.

Policy on collection of information from minors:

We do not knowingly collect personal information from children under the age of 18. By using the Services, you represent that you are at least 18 years old or that you are the parent or guardian of a minor and you grant consent to such minor’s use of the Services. If we learn that personal information from users less than 18 years old has been collected, we will deactivate any related accounts and will delete such information from our records.

If you believe we have collected data from a person under the age of 16 without proper consent, please contact us through any of the contact methods indicated below in the section entitled “Contact Us”.

Your rights with respect to your information:

You have the following rights with respect to any personal information we collect from you:

The right to know about information we have collected from you. These include rights to know:
- whether we collect your personal information
- the categories of information we collect, use, and share
- the purposes for which information is collected, used, or shared
- whether we sell your information to third parties
- the categories of third parties to whom we disclose your information
The right to delete your personal information.
The right to correct inaccurate information.
The right to opt out of sale or sharing of your data. Please note that you may later consent to the sale or sharing of your information after initially opting out.
The right to designate an agent to make these requests on your behalf. Please note that we may require the agent to provide proof that they have valid authorization to act on your behalf.
The right to limit use and disclosure of sensitive personal information to specific purposes
The right to not be discriminated against for exercising these rights.

You may exercise any of these rights by contacting us through any of the contact methods indicated below in the section entitled “Contact Us”. Upon receiving your request, we may need to verify your identity to determine that the request is being made by the actual owner of the personal information. Please note that we are not required or obligated to act on a request to provide or delete information that has been de-identified, nor are we required to re-identify information to respond to a consumer request.

If you have questions or comments about your privacy rights, you may contact us through any of the methods indicated in the section entitled “Contact Us”.

Customers Located in Europe and the UK

Privacy Rights. In compliance with the GDPR and the UK GDPR, we provide specific rights for individuals who reside within the European Economic Area (“EEA”) and the United Kingdom (“UK”). These additional rights include:

Right to be informed about the use and collection of your personal information.
Right to view and access your personal information.
Right to request amendment or rectification of outdated or incorrect personal information.
Right to request deletion of your personal information.
Right to restrict processing or otherwise withdraw consent to the processing of Your personal information.
Right to obtain copies of your personal information in machine-readable electronic format
Right to object to the processing of your personal information.

Legal Bases. The GDPR requires data processors to have a valid legal basis for processing your data. Depending on the particular data involved, we may rely on one or more of the following bases to process your personal information:

Consent. We may process your information if you have given us permission to use Your information for a specific purpose. You may withdraw your consent at any time by using the contact details provided in the section entitled “Contact Us”. However, we may still lawfully process information for which consent received before its withdrawal.
Performance of a Contract. In some circumstances, we may require your personal information to carry out a contract or other agreement with you. If you do not provide such required information, we may be unable to provide certain products or services.
Legitimate Interests. We may process your information when needed for legitimate business interests, such as analytics, diagnostics, and fraud prevention to improve our products and Services as well as your experience with us and our website.
Legal Obligations. We may process your information when necessary to comply with a legal obligation.
Vital Interests. We may process your personal information when we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

Data Transfers. We may transfer data containing your personal information to countries other than the country in which the data was originally collected, including to the United States. By using the Services, you acknowledge that any personal information you provide to us may be transferred to the United States or other countries and may be hosted on servers located in the United States or other countries, and you consent and authorize us to transfer, store, and process your information to and in the United States and other countries.

Data Subject Access Requests. You may exercise any of the above rights by contacting us through any of the methods indicated in the section entitled “Contact Us”, and we will make our best efforts to fulfil your requests in a timely manner.

Complaints: If you are located in the EEA or the UK and you believe we are unlawfully processing your personal information, you have the right to complain to your local data protection supervisory authority, which can be found here for the EEA: https://edpb.europa.eu/about-edpb/about-edpb/members_en or here for the UK: https://ico.org.uk/

Do not track policy

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. 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 signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

Updates to this notice:

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

Contact Us:

If you have questions or comments about this notice, you may email us at Sutphen@SutphenCorp.com or by post to:

Sutphen Corporation

P.O. Box 158

Amlin, OH 43002

United States

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