PRIVACY POLICY

SECURITY POLICY

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Privacy Policy

Jaclo Industries (“Jaclo”) has created this Privacy Policy in order to disclose to users (“Users”) of its internet site (the “Website”) its information collection and information transmission practices. All use of the Website is also subject to Jaclo’s General Terms of Use (the “Terms of Use”). Please note that this Privacy Policy may occasionally be modified without notice by Jaclo, and your continued use of the Website following such changes shall be deemed an acceptance of any such modifications. This Privacy Policy applies only to information that is collected on the Website by Jaclo or which Users provide on the Website. It does not apply to information collected by Jaclo that is not obtained through the Website, or information collected by any third party. If you do not agree with this Privacy Policy, please do not use the Website. Notwithstanding the foregoing, if we make any material changes to how we treat Users’ personally identifiable information, we will post a notice on the Website or, if you are a registered User who has created an account and provided an email address, we will send notification of material changes by electronic mail [PLEASE CONFIRM WITH CONSULTANT THIS IS METHOD OF ADVISING AS TO CHANGES IN POLICY.].

1. Children Under 18. The Website is not intended for use by children under 18 years of age. Jaclo does not knowingly collect personal information from children under 18 years of age. If you are under 18 years of age, please do not provide provide any information about yourself to Jaclo, such as your name, address, telephone number, or e-mail address. If we determine that we have collected or received personal information from a child of less than 18 years of age without verification of parental consent of the child to such disclosure, we will delete that information. If you have reason to believe that the Website might have any information from or about a child of less than 18 years of age, please contact us at _________________________ [insert contact information].

2. Non-Personally Identifiable Information. Jaclo does automatically gather quantitative information about activity on the Website which does not individually identify you, such as information about your internet connection, internet browser or device on which the Website is viewed, the number of visits you make to the Website, the time/length of visits, and product information viewed on the Jaclo Website, and Jaclo may use this information on an aggregated, anonymous basis. While Jaclo may make use of session-based “cookies,” personally identifiable information (such as email addresses and names) is not gathered by cookies (which are files transferred by the Website to a user’s device to store information regarding the user’s Website use). The non-personally identifiable information collected may be used by Jaclo for your convenience during your use of the Website or for generation of targeted advertisements by Jaclo. You can adjust your internet browser settings to reject cookies, although you may affect the function of the Website. By using the Website with your browser settings set to allow cookies, you consent to Jaclo’s placement of cookies on your device. The non-personally identifiable information that is collected is used to customize the Website and information provided on the Website to User preferences, to estimate the number of Users, to learn about usage patterns, to store information about User preferences, to diagnose technical issues with the Website, and to facilitate navigation of the Website.

3. Personally Identifiable Information Jaclo does not automatically collect personally identifiable information. Users must voluntarily provide such personally identifiable information. The Website permits the creation of projects/portfolios, which require user registration and creation of a user account. Certain portions of the Website may also be restricted solely to Dealers (as defined in the Terms of Use). As to these restricted access areas, provision of personally identifiable user information is required (such personally identifiable information including, without limitation, names, mailing addresses, telephone numbers, email addresses, etc.). Similarly, in order to receive additional information about Jaclo’s products, you may be asked to provide personally identifiable information (such as names, mailing addresses, email addresses, and telephone numbers). Restricted Access Areas that are restricted to Dealers are also subject to separate Terms and Conditions of Use, which are available at _______________________. Users who provide personally identifiable information to the Website have the opportunity to review and alter the personally identifiable information provided by them to Jaclo in connection with such registration, including the opportunity to request removal of information provided by them from Jaclo’s Website databases, or removal from Jaclo electronic mailing lists. You can request removal of your personally identifiable information from the Website or un-subscription from Jaclo’s e-mail communications by check-box or un-subscribe from future Jaclo communications by contacting _____________________ [insert email address]. It may take Jaclo several days to process your removal or un-subscription requests, and you may briefly continue to receive communications after you have requested removal. Jaclo may use the personally identifiable information you provide to Jaclo to contact you via mail, telephone or electronic mail to provide you with additional information about Jaclo products or promotions, unless you opt out. Jaclo may also use your contact information to respond to communications from you. JACLO WILL NOT SHARE YOUR PERSONALLY IDENTIFIABLE INFORMATION WITH THIRD PARTIES (OTHER THAN JACLO’S SERVICE PROVIDERS FOR TECHNICAL PURPOSES) AND WILL NOT SHARE IT WITH THIRD PARTIES FOR DIRECT MARKETING PURPOSES. JACLO SHARES IT ONLY WITH THOSE INDIVIDUALS WHOSE DUTIES REQUIRE ACCESS TO SUCH INFORMATION, AND WITH SERVICE PROVIDERS WHO REQUIRE THIS INFORMATION TO PERFORM THEIR DUTIES, AND SUCH INDIVIDUALS AND SERVICES PROVIDERS HAVE BEEN ADVISED THAT SUCH INFORMATION IS CONFIDENTIAL AND MUST BE PROTECTED AND UTILIZED SOLELY FOR THE PURPOSES FOR WHICH IT WAS PROVIDED. Notwithstanding the foregoing, Jaclo may provide such information to a buyer or other successor in the event of a sale or transfer of Jaclo (whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding).

4. Security All Jaclo personnel and third party service providers have been advised that personally identifiable information is confidential and must be protected. Your use of social media features, even if linked to the Website, is governed by the applicable privacy policy of the third party social media companies that provide such features. Please note that Jaclo will never make an unsolicited request via telephone or electronic mail for your user name or password- please do not provide this information to individuals making such requests who claim to be making such a request on behalf of Jaclo. Jaclo may provide you with notices about your account, including without limitation, notifications about changes to the Website and any products or services provided through the Website. Please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. Jaclo does not and cannot guarantee the confidentiality of any communications with the Website. If you wish to communicate confidential information to Jaclo, please contact Jaclo via non-cellular telephone. Please comply with any specific instructions provided at restricted access areas of the Website to assist Jaclo in safeguarding your personally identifiable information. It is your responsibility to ensure the security of your user account and password, as disclosure by you to third parties of your user account or password will result in such third parties having access to information provided by you to the Website. Jaclo employs a number of administrative and technical precautions, including without limitation, passwords, encryption technology, and other system safeguards. Jaclo reserves the right to disclose your personally identifiable information and to provide to it to third parties (other than service providers of Jaclo) in the event that it has a good-faith belief that disclosure of such information is required by law, government agencies, or legal process, or to protect the rights, property, security or safety of Jaclo or its affiliates, employees, Dealers, contractors, suppliers and customers (including in connection with investigation of suspected criminal activity or purported copyright infringement). Jaclo’s right to disclose information includes registration, account and personally identifiable or non-personally identifiable information.

5. Contact Information. If you have questions or comments regarding this Privacy Policy, contact us at ________________________ [insert contact information].