Privacy Policy

Last updated: 9/11/2023

This Privacy Policy describes Brownells' ("We," "Us," or "Our") policies and procedures on the collection, use, and disclosure of our users' ("You" or "Your") personal information when You use the Service and tells You about Your privacy rights and how the law protects You. This Privacy Policy governs the websites we and our affiliates, subsidiaries, and related entities operate.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to, your:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Bank account information in order to pay for products and/or services within the Service
• Usage Data

When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:

• Date of birth
• Passport or National ID card
• Bank card statement
• Other information linking You to an address

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. Learn more about cookies: All About Cookies.

We use both session and persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies
  Type: Session Cookies
  Administered by: Us
  Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Functionality Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

• Tracking and Performance Cookies
  Type: Persistent Cookies
  Administered by: Third-Parties
  Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.

How to Disable Cookies

Some cookies are required for our website to function, as outlined above, and disabling them may prevent you from using certain aspects of our sites. However, to protect your privacy, you may choose to change your browser settings to disable non-essential cookies. The "Help" feature on most browsers provides instructions on how to prevent your browser from allowing new cookies and how to disable cookies. Please also use the following links for more information on how to manage popular browsers. For more information regarding cookies, please see www.aboutcookies.org or www.allaboutcookies.org.

• Google Chrome
• Safari
• Mozilla Firefox
• Microsoft Edge
• Internet Explorer

Use of Your Personal Data

We may use your Personal Data for the following purposes:

• To provide and maintain our Service: To monitor the usage of our Service, to process payments from you, for customer service purposes.
• To manage Your Account: To manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: For the development, compliance and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication. We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
• To provide You with updates: Including news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• With other users: When You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

Retention of Your Personal Data

We will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Disclosure of Your Personal Data

Service Providers

We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, for email marketing, to contact You, etc.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g., payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.

With Affiliates

We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

With Business Partners

We may share Your information with Our business partners to offer You certain products, services, or promotions.

Business Transactions

If We are involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, We may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

We may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of Brownells
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

How We Respond to Browser "Do Not Track" Signals

Some web browsers incorporate a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. California law requires that website operators disclose how they respond to a Do Not Track signal and whether other third parties may collect personally identifiable information about an individual's online activities from their site or service.

We currently do not respond to "Do Not Track" signals. As the technology and communication between browser and website improves, we may make changes to our policy. Please refer to the sections titled "Personal Information We Collect Directly" and "Personal Information We Collect Indirectly" for additional information.

Your California Privacy Rights

We do not share your personal information with unaffiliated third parties for their own independent marketing purposes without your consent. California residents may request the categories of personal information that we shared with third parties for the third parties' direct marketing purposes during the previous calendar year, if any. Written requests may be sent to the following address:

You must write "Your California Privacy Rights" at the top of your inquiry. We will respond within 30 days to requests regarding the categories of personal information that we shared with third parties for their own direct marketing purposes within the previous calendar year. Requests for this information that come to Brownells by other means may result in a delayed response.

The following applies solely to California "consumers" as defined in Section 17014 of Title 18 of the California Code of Regulations. We adopt this notice to comply with the California Consumer Privacy Act ("CCPA"). This policy describes our collection, use, disclosure, and "sale" (if applicable) of "personal information" of California consumers as these terms are defined under the CCPA.

Information We Collect

We have collected the following categories of sensitive personal information about you:

Disclosure of Personal Information for a Business Purpose

Within the preceding twelve (12) months, Brownells has disclosed the following categories of personal information to its service providers for the business purpose of performing services on behalf of Brownells such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of Brownells.

• Identifiers;
• Customer Records;
• Protected Classifications;
• Commercial Information;
• Internet/Network Activity;
• Geolocation Data;
• Audio, Electronic, Visual, etc. Information; and
• Inferences.

Sale and Sharing of Personal Information

Brownells does not currently sell personal information as the term is defined under the CCPA, however, we do share the following categories of personal information to our cookie and tracker providers:

• Internet/Network activity; and
• Geolocation data.

Brownells does not knowingly sell personal information of California consumers under the age of sixteen (16) years.

Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:

• The right to know. You have the right to request that we disclose to you the personal information we have collected, used, disclosed, or sold about you in the previous twelve (12) months. You may also request a copy of the personal information we have collected on you over the past twelve (12) months. See the "Exercising Your CCPA Data Privacy Rights" section for instructions on submitting a right to know request.
• The right to opt out of the sharing of Personal Data. You also have the right to ask the Company not to share your Personal Data to third parties. You can submit such a request by clicking on the "Your Privacy Choices " link at the bottom of the page and update your preferences.
• The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months. Once we receive and confirm your verifiable request, we will delete and direct our service providers to delete your personal information from our records, unless an exception applies. See the "Exercising Your CCPA Data Privacy Rights" section for instructions on submitting a right to deletion request.
• The right to correct inaccurate Personal Data: You have the right to request that we correct any inaccurate personal information that we have collected from you and retain. Once we have received the personal information from you to be updated, we will update the information where necessary within our systems. See the "Exercising Your CCPA Data Privacy Rights" section for instructions on submitting a right to correction request.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights. Therefore, it is Our policy to ensure we do not discriminate against you for exercising these rights, unless permitted by the CCPA, including by:
• Denying goods or services to You
• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to You; or
• Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
• To verify your request, we will compare the pieces of information that you submit with your request to the Personal Information we have on file to confirm that the data we have identified corresponds to you, and that the person submitting the request is authorized to do so. We may require you to provide additional pieces of personal information to allow us to verify your identity, such as your email address, phone number, account number, etc. If we cannot comply with a request, we will explain the reasons in our response.
• You may designate an authorized agent to submit a request on your behalf. Pursuant to the CCPA: You may designate, in writing or through a power of attorney, an authorized agent to make these privacy requests on your behalf to exercise these rights. An authorized agent may submit a request on your behalf if you have provided the authorized agent with power of attorney in accordance with California law. If this has not occurred, we will require the agent to provide proof that you have authorized it to act on your behalf and may require you to verify your own identity with us directly before we accept a request. We will do this by requiring the authorized agent to present verifiable written authorization from you that you have provided the agent with permission to submit the request and independently verify the agent's own identity with Brownells.

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA listed above, and if you are a California resident, see the “Contact Us” section below or submit a request here.

How We Store Your Personal Information

Please note, we will not retain your personal information for longer than is reasonably necessary for the disclosed purposes outlined in the "Information We Collect" section.

Financial Incentives

Brownells provides consumers with a discount code on their birthday via email. Under the CCPA, this is considered a financial incentive program. Consumers opt into receiving this financial incentive by providing their date of birth during the marketing email sign up process. The birthday discount code is provided via email to the email address provided by the consumer upon the consumer's birthday. Consumers may opt out of this financial incentive at any time by clicking on the unsubscribe link included in the footer of our emails.

The information Brownells has collected through this financial incentive enables Brownells to establish a relationship with its customers and is valued by Brownells to provide its customers with a customized offer each year. In determining the value of personal information collected as part of the birthday discount program, we considered the revenue generated from the use of the birthday discounts, which is reasonably correlated to the value provided to the consumer through the personalized birthday discount.

Your Colorado, Connecticut, and Virginia Privacy Rights

We adopt this notice to comply with the Colorado Privacy Law ("CPA"), the Connecticut Privacy Law ("CTDPA"), and the Virginia Consumer Data Protection Act ("VCDPA"). This policy describes our collection and use of "personal data" of Colorado, Connecticut, and Virginia "consumers" as these terms are defined under these laws.

To view the categories of personal data which we may collect from you, please see the section above titled "Types of Data Collected." To view the purposes of processing, please see the section above titled "Use of Your Personal Data".

Your Rights under the CPA, CTDPA, and VCDPA

Under the CPA, CTDPA, and VCDPA, residents are provided with certain privacy rights which they may exercise.

The Right to Opt-Out: You have the right to opt-out of the processing of your personal data for the purposes of targeted advertising. If you would like to opt out of targeted advertising, please click on the "Your Privacy Choices " link at the bottom of the page and update your preferences.Please note, we do not sell your personal data as defined by the CPA, CTDPA, and VCDPA.

The Right to Know: You have the right to confirm whether or not Brownells is processing your personal data and to access such personal data.

The Right to Data Portability: You have the right to obtain a copy of your personal data that you previously provided to Brownells in a portable, and to the extent technically feasible, readily usable formal that allow you to transmit data to another controller without hindrance, where the processing is carried out by automated means.

The Right to Correct: You have the right to request that Brownells correct any inaccurate personal information that we have collected from you and maintain. Once we have received the personal information from you to be updated through a verifiable request, we will update the information where necessary within our systems.

The Right to Delete: You have the right to request that we delete any of your personal information that we collected from you and retained. Once we receive and confirm your verifiable request, we will delete and direct our service providers to delete your personal information from our records.

Exercising Your CPA, CTDPA, and VCDPA Data Protection Rights

In order to exercise any of Your rights under the CPA, CTDPA, and VCDPA listed above, and if you are a Colorado, Connecticut, or Virginia resident, see the "Contact Us" section below or submit a request here.

Notice to Nevada Residents

As a Nevada consumer, you have the right to request that a company refrain from exchanging your personal information to specific parties in exchange for financial compensation. This right remains valid regardless of whether your personal information is presently being sold. If you desire to exercise this privilege, see the “Contact Us” section below or submit a request here.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: customersupport@brownells.com
• By visiting this page on our website: www.brownells.com
• By phone number: 800.741.0015