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// PRIVACY POLICY

// PRIVACY POLICY

Last Update: April 21, 2020

Brass LLC and its licensors and affiliates (“Brass,” ”we,” “us” or “our”) know that you are concerned about privacy. We are committed to protecting it through our compliance with this Privacy Policy. We also sell and lease vehicles that collect other types of personal information and vehicle data and use a separate owners privacy policy to explain our practices related to such information and data.

This Privacy Policy applies to information that we may collect from you or that you provide to us and it explains how we collect, use, maintain, protect, disclose and safeguard this information. By providing information to us or by using our products or services, you agree to the terms and conditions of this Privacy Policy. The terms “you” and “your” refer to the person using or accessing the Website.

This policy applies to information we collect:
– Through this website or our other website on which this Privacy Policy is posted or referenced (collectively, our “Website”);
– When you sign up for a newsletter, provide information to Brass in online forms, emails, texts or other electronic messages exchanged
between you and Brass or provide information to Brass through our social media pages;
– Offline, such as when you attend one of our events, sign up for a information or promotions or contact our Customer Services Team by telephone; and
– From other sources, such as public databases, joint marketing partners, authorized Brass retailers or service centers, third party suppliers and vendors,
and contact information platform providers.
– It does not apply to information collected by any third party, including through any application or content that may link to or be
accessible from or on our Website.

Please review this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Website, use our products or services or otherwise provide Brass with information. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website or our products or services after we make changes is deemed to be acceptance of those changes, so please check back periodically for updates.

// CHILDREN UNDER THE AGE OF 13

Our Website is not intended for, or designed to attract, children under 13 years of age.
We do not knowingly collect personal information from children under 13.

// Collection, Use of Sharing an Information

Information We Collect
We collect several types of information from and about users of our Website and our products and services, including information:
By which you may be personally identified or contacted online or offline including your name, company name, postal address, telephone number, e-mail address, and any other information that Brass collects that is defined as personal or personally identifiable information under an applicable law (“Personal Information”);
That is about you but individually does not identify you and
About your internet connection, the equipment you use to access our Website and usage details.

How We Collect Information.
We may collect this information from you in a variety of ways, including:
– Directly from you when you provide it to us;
– Automatically as you navigate through our Website; and
– From third parties, for example, our business partners, marketing partnerships and public databases.

Information that You Provide to Us.
The information that we collect from you may include:
– Information that you provide by filling in forms on our Website. This includes information provided at the time of registering for an account to use certain features
of our Website, posting User Contributions or requesting services. Brass may also ask you to provide information when you report a problem with our Website;
– Records and copies of your correspondence (including your email address) if you contact us;
– Your responses to surveys that we might ask you to complete for research purposes; and
– Your search queries on the Website.

You also may provide information to be published or displayed (“Posted”) on certain areas of the Website or transmitted to other users of the Website or third parties, such as comments on our social media pages (collectively, “User Contributions”). Your User Contributions are Posted on and transmitted to others at your own risk. Although we limit access to certain features, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect through Automatic Data Collection Technologies
When you visit our Website or otherwise use our online services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns including:
– Details of your visits to our Website, including traffic data, location data, information collected through cookies and other tracking technologies, and the
resources that you access and use on the Website, such as the site you came from and exited to, date/time stamp, and pages visited.
– Information about your computer and internet connection, including your Media Access Control (MAC) address, IP address, operating system,
screen resolution, browser type, device manufacturer and type, mobile device ID, and Internet Service Provider.

Our third party advertising partners may use automatic data collection technologies on our Website in order to help display advertisements that you see on our website and other websites you may visit. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services that use those third party’s advertising services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
– Estimate our audience size and usage patterns.
– Store information about your preferences, allowing us to customize our Website according to your individual interests.
– Recognize you when you return to our Website.

The technologies we or our third party business partners may use for this automatic data collection may include:
– Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by
activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website.
Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
– Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs,
pixel tags, and single-pixel gifs) that permit Brass, for example, to count users who have visited those pages or opened an email and for other
related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
– Analytics tools. We use website and application analytics services provided by third parties that use cookies and other similar technologies to
collect information about website or application use and to report trends, without identifying individual visitors. The third parties that provide us
with these services may also collect information about your use of third-party website. One of these third party analytics services is Google Analytics.
You can learn about Google’s practices in connection with this information collection by viewing their Privacy Policy located here:
www.google.com/analytics/learn/privacy.html.

How We May Use Your Information.
We may use information that we collect or that you provide to us, including any Personal Information, to communicate with you, to provide and improve our Website and our products and services, and for other purposes. Examples of how we use information for these purposes include:
– To respond to inquiries and fulfill your requests, such as to send you newsletters or product information, alerts or brochures or to assist us
with resolving questions regarding our Website;
– To provide purchase-related customer service, such as to contact you with service information;
– To advise you of important safety-related information;
– To perform research and analysis to develop and promote new products and services and to improve or modify our Website or our existing products and services;
– To send administrative information to you, such as information regarding changes to our terms and policies;
– To enhance our lists with information from other sources;
– To personalize your experience by customizing the online and offline communications you receive from us, our affiliates and others;
– To allow you to participate in Brass events and activities;
– To protect the information collected against fraudulent, illegal or otherwise unauthorized activity, including any investigation into such activity;
– To allow you to participate in interactive features on our Website;
– In any other way we may describe when you provide the information; and
– For any other legitimate business purpose.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information
We may disclose without restriction any aggregated information about our users and information that does not identify any individual.
We may disclose Personal Information that we collect or you provide, as described in this privacy policy:

– To our subsidiaries and affiliates;
– To Brass labs, distributors and employees;
– To contractors, service providers, and other third parties 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 a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or
all of Brass’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held
by Brass is among the assets transferred;
– To fulfill the purpose for which you provide it;
– For any other purpose disclosed by us when you provide the information; and
– With your consent.

We may also disclose your personal information:

– To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
– To enforce or apply our Terms of Use and other agreements.
– If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Brass, our customers or others.
This includes exchanging information with other companies and organizations for the purposes of fraud protection.

// Choices about how we use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
– Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable
or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
– Promotional Offers from Brass. If you do not wish to have your email address/contact information used by Brass to promote our own or third
parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time
by sending us an email stating your request to info@brasscbd.com. If we have sent you a promotional email, you may send us a return email asking
to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase,
contract communication, product service experience or other transactions.

// Links to the Third Party website

The Website may contain links to websites provided by independent third parties (“Third Party Sites”). Brass is not responsible for the content, privacy, or practices of the Third Party Sites and this Privacy Policy does not apply to the Third Party Sites.

// Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@brasscbd.com or write us at: 1309 Coffeen Ave, Ste 1200, Sheridan, WY 82801

// OPT-IN (For Canadian Residents)

BY SUBMITTING PERSONAL INFORMATION TO US, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting us at our contact as provided below. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you. If you provide us with personal information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

// International Users

If you are visiting the Website from outside of the United States, your connection may be made through and to servers located in the United States, and all information you provide may be processed and maintained in our web servers and internal systems located within the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to ensure that your privacy is protected. By using our Website, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy. By using the Website, you authorize the export of Personal Information to the United States and its storage and use as specified above when you provide such information to us.

// Notice Regarding Unauthorized Access or
Disclosure of Personal Information

For the purposes of any applicable law regarding notification of persons whose Personal Information was, or is reasonably believed to have been, acquired by an unauthorized person, any required notification may, where permitted by law, be made by the use of e-mail, telephone, fax or mail (including a notice printed in an available area of a bill or statement) or by posting a notice on the Site. The specific means used is determined by us, and we will use our best judgment based on the circumstances. Where any notice is to be sent to a specific address or number (such as an e-mail address, physical address, telephone number, etc.), we will use the latest available address in our records. YOUR CONTINUED USE OF THE WEBSITE IS DEEMED TO BE AGREEMENT TO THIS MEANS OF NOTIFICATION.

// Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website, such as our Forum. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we use reasonable safeguards to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

// Accessing and Correcting your Information

To correct or update your personal information, contact us at
Telephone: (949) 679-8785
Available Monday-Friday, 9:00 a.m. – 5 p.m. PST

Mailing Address:
Brass, LLC
Attention: Client Services
1200 Coffeen Way, Ste 1200
Sheridan, WY 82801

or via email at
info@brasscbd.com

We will use reasonable efforts to update any inaccuracies in your information. In some cases, however, we may limit or deny your request if the law permits or requires us to do so, if your request infringes on the privacy of other individuals or internal procedures, or if we are unable to verify your identify.

// Do Not Track

Our Website does not support Do Not Track at this time. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across website when you have not vinteracted with that service on the page.
For all the details, including how to turn on Do Not Track, visit www.donottrack.us

// Choice of Law and Venue

In the event of any dispute or claim relating to this privacy policy, you agree to resolution of such dispute in the state or federal courts located in Orange County, California, in accordance with California law.

// Change to Our Privacy Policy

We will post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page as the effective date. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

// Contact Information

If you have any questions, concerns or inquiries about this privacy policy or our privacy practices, contact us at:

Telephone: (949) 679-8785
Available Monday-Friday, 9:00 a.m. – 5 p.m. PST

Mailing Address:
Brass, LLC
Attention: Client Services
1200 Coffeen Way, Ste 1200
Sheridan, WY 82801

or via email at
info@brasscbd.com