PRIVACY POLICY

LAST UPDATED: April 27, 2025

This Privacy Policy ("Policy") explains how Jack Hutton LLC (“we,” “us,” or “our”) collects, uses, shares, and safeguards your personal information when you interact with our website, byjackhutton.com, and any related services, platforms, or locations where this Policy is displayed or referenced (“Platform”). It also describes your rights regarding your personal information and how you can exercise those rights. This Policy, along with our Terms of Use, governs your use of our Platform and services.

INFORMATION WE COLLECT

We collect information from and about you when you visit our Platform, reach out to us by email, submit online forms, place orders, or otherwise engage with our services. This may include personal information — information that identifies, relates to, or could reasonably be linked to you directly or indirectly, such as your name, address, email, phone number, and payment details. It may also include records of your purchases, browsing activity, geolocation data, and inferences drawn from other information to create a profile about your preferences or characteristics. Publicly available information may also be collected where permitted by law.

The type of personal information we collect depends on how you interact with us, and may include:

• Contact Information: Such as your name, mailing address, email address, and phone number. For instance, we collect this information when you create an online account, sign up for communications, or participate in a promotion or survey.

• Payment Information: When you purchase products through our Platform, we collect your billing and shipping address, and your payment method details, such as credit card information.

• Information You Submit: We collect the information you provide when you contact us through forms, customer service emails, or other communications.

• Social Media Information: We may collect personal information you make publicly available on our social media pages, including your profile details and posts.

• Demographic Information: We may collect your age, gender, zip code, birthday, and interests to better understand our customer base.

• Purchase Information: We maintain records of your purchases and transaction history with us.

• Device Information: We collect information about the devices you use to access our Platform, including your device type, IP address, operating system, and browser type.

• Location Information: We may collect information about your precise or approximate location through your device when you use our Platform.

• Surveillance Information: If you visit any physical locations associated with us, we may use video surveillance for security, loss prevention, and operational purposes.

• Other Usage Information: We gather details about how you navigate and interact with our Platform, including the pages you view, links you click, time spent on pages, and other analytical data. We may also monitor interaction with our communications (like emails) and may use tools from third parties to support this data collection, including tools aimed at detecting fraud and enhancing security.

HOW WE COLLECT INFORMATION

We collect personal information passively.

We gather personal information about users over time and across different websites, applications, and devices when you engage with our Platform. Our service providers and partners may also collect information through these means. This includes when you browse our website from any device, enable location-based features, or click links to our partners or collaborators. We and our partners use technologies like cookies, web beacons, flash cookies, and other tracking tools to facilitate this collection.

We collect personal information directly from you.

We collect information directly when you create an account, make a purchase, participate in promotions, fill out forms, contact us, or engage with us through our social media channels.

We collect personal information from third parties.

We may collect personal information from third-party sources or public databases to comply with legal requirements or enhance our services. These sources may include analytics providers, Internet service providers, advertising networks, and social media platforms.

We combine personal information.

We may merge information collected offline (such as from an in-person event) with information collected online. We also combine information collected from multiple devices or from third parties with data we already maintain about you.

HOW WE USE YOUR INFORMATION

We use personal information to provide our products and services.

We use your information to fulfill orders, deliver services, manage accounts, process payments, arrange repairs, offer tailored shopping experiences, and operate and improve our Platform.

We use personal information to better understand you and improve our offerings.

We analyze information to enhance the quality of our website, products, and services. We use it to personalize your experience and tailor our marketing and communication efforts to your interests.

We use personal information to communicate with you.

We may contact you to respond to your inquiries, provide customer service, and deliver transactional communications such as order confirmations and updates.

We use personal information for marketing purposes.

We may use your information to inform you about new products, services, promotions, and events that may interest you. We may also engage in interest-based advertising across different platforms and devices, always in compliance with applicable laws.

We use personal information for account management and service updates.

We may contact you about your account, important updates to our Platform, service alerts, and policy changes.

We use personal information for security and legal purposes.

We use personal information to detect, prevent, and address fraud, breaches, or other harmful or illegal activities. We may also use it for auditing, compliance, and legal obligations.

We use personal information for other internal purposes.

This includes maintaining transaction records, conducting internal research, business administration, insurance purposes, and fulfilling other legal and regulatory obligations.

HOW WE SHARE YOUR INFORMATION

We share personal information with service providers.

We may share your personal information with trusted service providers who perform functions on our behalf, including payment processing, order fulfillment, customer service, email communications, fraud prevention, and marketing support.

We share information with business partners.

We may share your information with trusted partners who co-sponsor events or promotions with us. Some partners may also use tracking technologies on our site. Under certain privacy laws, this may constitute a “sale” or “sharing” of personal information. You may have the right to opt out of such practices, as explained below. Importantly, we do not “sell” personal information for direct monetary compensation.

We may share information within our corporate family.

We may share your information with our parent company, subsidiaries, affiliates, or successors for operational, administrative, and service-related purposes.

We may share personal information in business transfers.

If Jack Hutton LLC undergoes a merger, acquisition, restructuring, or asset sale, we may transfer personal information to the relevant third party as part of that transaction.

We may share personal information for legal or safety reasons.

We may disclose personal information if required by law, legal process, or government request. We may also share information to protect the rights, safety, and property of Jack Hutton LLC, our customers, or others.

RETENTION OF PERSONAL INFORMATION.

You have certain choices about how we use your information. Certain choices you make are browser and device specific.

We retain each type of personal information set forth herein for as long as necessary to fulfill the purpose for which it was collected, including to meet accounting, legal and/or reporting requirements, and where required to defend or assert against legal claims, until the end of the applicable retention period or until a particular claim has been settled. We use the following criteria to determine how long to retain the personal information: (i) your requests to us regarding your personal information, (ii) technical considerations and the levels of protection in place for it, (iii) legal obligations to retain it or for our own legal purposes and (iv) generally our relationship to you.

YOU HAVE RIGHTS REGARDING YOUR INFORMATION.

You have certain rights about how we use your personal information. Certain rights are browser and device specific.

Marketing Communications

You may opt out of receiving our marketing communications. You may opt out of receiving our promotional e-mails or text messages by following the instructions included with the communication. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries.

We use tracking technologies.

We collect personal information about users when you use the Platform. Third parties may also collect personal information this way on our Platform. To do this, we use several common tracking tools. Our vendors and partners may also use these tools. These may include cookies. Cookies are small files that download when you access certain websites. To learn more, visit here. We, or our vendors and partners, may also use web beacons, flash cookies, and other tracking technologies.

We use tracking technologies for a variety of reasons.

We use tracking tools to recognize new or past users, store your password if you have registered on our website, improve our Platform, products, or services, serve you with interest-based or targeted advertising, observe your behaviors and browsing activities over time across multiple devices or other platforms, and to better understand the interests of our Platform visitors.

We may engage in on-line behavioral advertising.

We and our partners may display interest-based advertising using information gathered about you over time across multiple websites, devices, or other platforms. Interest-based advertising or “on-line behavioral advertising” includes ads served to you after you leave a website, encouraging you to return. These ads may be served after you leave our website, or after you leave the websites of third parties. They also include ads we and our partners think are relevant based on your browsing habits or on-line activities. These ads might be served on websites or applications. We might serve these ads, or third parties may serve ads. They might be about our products or other company's products. As described above, we work with third parties who help gather this information. These third parties might link your name or e-mail address to other information they collect. That might include past purchases made off-line or on-line. Or, it might include on-line usage information.

You can control certain tracking tools.

Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. Please note however, that if you choose to make any such elections it could affect the availability and functionality of our website. To control flash cookies, which we may use on our website from time to time, you can go here; flash cookies cannot be controlled through your browser settings.

Opt-Out Preference Signals.

Opt-out preference signals allow consumers to notify businesses that they do not want their personal information shared with third parties for advertising and other purposes without having to make a specific request each time they visit a site, for example by placing an extension on a user’s browser. Please be advised that although we may do so in the future we do not currently process these signals inclusive of the Global Privacy Control signal.

You can opt out of targeted-behavioral advertising

You can reject all cookies except functional cookies using our cookie preference tools, including opting out of targeted-behavioral advertising based on information obtained from our website. Keep in mind that if you visit us from a different device or browser, or clear cookies, you may need to reselect your preferences. Certain choices you make may be browser and/or device specific.

THIS PLATFORM AND CHILDREN.

Our Platform is meant for adults. We do not knowingly collect personally identifiable information from children under the age of 16. If you are a parent or legal guardian and think your child has given us information, you may contact us by using the “Client Service” section at the bottom of our website and clicking on the button that says “Contact Client Services Team” or using the contact information set forth below in this Policy. Please mark your inquiries “Children’s Information Request.” Parents, you can learn more about how to protect children's privacy here.

SECURITY

We use standard security measures.

The Internet and information storage are not 100% secure. We cannot guarantee that any of your personal information stored or sent to us will be completely safe. We encourage you to use caution. We use reasonable technical, administrative, and physical controls, procedures, and practices to safeguard personal information under our control (taking into account the nature of the personal information) from unauthorized or illegal access, destruction, use, modification, and disclosure. If a username and password are needed to access certain areas of our Platform it is your responsibility to protect them. To the full extent allowable by applicable law you acknowledge and agree that we are not responsible or liable if any information about you is intercepted, accessed, and/or used by any unintended recipient. If you believe that the security of your communications or personal information has been compromised please notify us immediately.

WE MAY LINK TO THIRD-PARTY SITES OR SERVICES WE DO NOT CONTROL.

You may be able to access certain third-party sites from our website.

For example, this may include social media sites. This Policy does not apply to those third-party sites.

We strongly advise you to check the privacy policies of all third-party sites you visit to find out how they are treating your personal information. We are not responsible for these third parties’ practices.

RIGHTS OF CONSUMERS IN APPLICABLE STATES REGARDING ACCESS AND CONTROL OVER PERSONAL INFORMATION

Certain state privacy laws in the U.S. such as California, Virginia, Colorado, Connecticut, and Utah may offer certain additional rights to you as detailed below, as applicable. These state laws include the California Privacy Rights Act of 2020, as amended by the California Privacy Rights Act of 2020 (“CPRA”).

The Right to Request Access to or Know Personal Information

The right to request and receive the categories and specific pieces of personal information we have collected about you, the categories of sources from which the personal information is collected, the business purpose for collecting the information, the categories of third parties with whom we share personal information, the categories of information that we sell or disclose to third parties, the length of time we intend to retain each category of information or if that’s not possible the criteria used to determine that information, and the right to confirm whether we process your personal information and access it in a portable, and to the extent technically feasible, readily useable format. In California, you may make such a request for this information for the 12-month period preceding your request up to twice a year. Please note however, that in states such as California we may refuse to disclose your personal information for certain reasons, such as being unable to verify your request, the request being manifestly unfounded or excessive, if it involves certain sensitive information (but we will tell you if we are collecting the type of information involved), if it would restrict our ability to comply with legal obligations, if necessary to exercise legal claims or rights or defend legal claims, or if the information is certain medical information, involves consumer credit reporting information or other types of information exempt from applicable law.

The Right to Correct Inaccurate Personal Information

The right to request that we correct inaccurate personal information, taking into account the nature of it and the purpose for which it was collected. Please note however, that in states such as California, we may refuse your request for certain reasons, such as being unable to verify your request, the request being manifestly unfounded or excessive, the information being publicly available, or if the information is certain medical information, involves consumer credit reporting information or other types of information exempt from applicable law.

The Right to Delete Personal Information

The right to delete the personal information we collect from you and to request that we tell our service providers to do the same under applicable law. Please note however, that in such states as California we may refuse your request for certain reasons, such as being unable to verify your request, to complete your transaction, provide a reasonably anticipated product or service or for certain warranty and product recall purposes, for certain internal uses that are compatible with reasonable consumer expectations or the context in which the information was provided, for certain business security practices, the information being publicly available, if it would restrict our ability to comply with legal obligations, if necessary to exercise legal claims or rights or defend legal claims, or if the information is certain medical information, involves consumer credit reporting information or other types of information exempt from applicable law.

The Right to Opt Out of the Sale or Sharing of Personal Information

California requires that we identify for the 12-month period prior to the date of this Policy the information that we have “sold” or “shared” about you. We do not knowingly “sell” personal information for direct monetary compensation, but the meaning of the word “sale” under certain privacy laws is broad and may include the transfer of information to other parties via cookies or other trackers. Moreover, we may “share” personal information for targeted advertising purposes through such methods. We may use these cookies or other trackers to personalize your experience, for statistical analysis or advertising and social media purposes, including to track your use of our website, offer you advertisements that target your interests, and/or to analyze the performance of our advertising. Without limiting any other provision set forth in this Policy, the information provided to others may include basic identification information; device and/or browser information and other unique identifiers such as cookies, beacons, pixel tags, mobile ad identifiers and similar technology, customer numbers, IP addresses, online identifiers, and other forms of persistent identifiers; Internet activity and other electronic network information including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or marketing; commercial information, including records of products and services purchased, obtained, or considered, and other purchasing or consuming histories; and inferences drawn from any of the information identified above to create a profile about you reflecting your preferences and behaviors.

Under the CPRA and certain other U.S. state privacy laws, you have the right to opt out of the sale and sharing of your personal information for targeted advertising purposes. As such, you have the right to reject all cookies except functional cookies (this option will opt you out of all sales and sharing for targeted advertising purposes). This can be achieved by clicking the “Do Not Sell or Share My Personal Information” link on the homepage of our website. Please note however, that (i) if you visit the website from a different device or browser or clear cookies you may need to reinput your elections and (ii) even if you opt out of the sale or sharing of your personal information, your use of our website may still be tracked by us and/or our service providers to the extent permitted by applicable law. Please note that in certain states such as California there are some exceptions to your opt-out rights, including where the information is publicly available, with respect to situations where the sale or sharing is necessary for us to comply with legal obligations, if necessary to exercise legal claims or rights or defend legal claims, or if the information is certain medical information, involves consumer credit reporting information or other types of information exempt from applicable law.

The Right to Consent to Collection of, or Limit the Use of Sensitive Personal Information in Certain States

If you are a resident of California, you may have the right to limit the use of sensitive personal information, and if you are a resident of Virginia, Colorado, Utah, or Connecticut, you may have the right to consent or opt out of the processing of sensitive personal information. As used in this Policy, sensitive personal information may mean, as defined by certain laws, information such as your exact geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, sex life or sexual orientation, health and genetic and/or biometric data, as and to the extent we may, if ever, collect such information from you. Under certain laws, it may also include social security numbers, driver’s license numbers, state identification cards, passport numbers, account log-ins, financial account information, and debit or card numbers in combination with security or access codes, passwords, or other account credentials. If we collect any such information, we only use it as may be necessary to provide goods and services to you and do not “sell” or “share” this sensitive personal information for targeted advertising purposes, and do not use such information to infer characteristics about you. If you are a Virginia, Colorado, Utah, or Connecticut resident we do not collect or process your sensitive data (as defined in those states) without your consent.

The Right to Appeal in Certain States

If you are a resident of Connecticut, Colorado, or Virginia, and we deny the exercise of any of the rights set forth above, you may appeal such denial by contacting us to appeal that decision by going to the “Client Service” section at the bottom of our website and clicking the button that says “Contact Client Services Team” or contacting us using the information set forth below in this Policy.

WE MAY UPDATE THIS PRIVACY POLICY.
From time to time, we may update our privacy practices. We will notify you of any material changes as required by law and post an updated copy on our website. Please check this page regularly for any updates.

FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS.
If you have any questions regarding how we use your information, or if you wish to request access to it, or request that we delete or correct it, please visit the “Client Services” section at the bottom of our website and click the button that says “Contact Client Services Team,” or reach out to us directly at:

Email: [business@byjackhutton.com]