Threecolts Legal Portal

Privacy Notice

Last Updated: January 9, 2025

Threecolts, LLC, a Delaware limited liability company, provides cloud-based services for businesses that sell on the Amazon.com platform (collectively, the “Services”). This Privacy Notice (“Privacy Notice”) describes how Threecolts, LLC and its parents, subsidiaries, or affiliates (collectively with Threecolts, LLC “Threecolts” or, throughout, “Company”) collect, use, disclose, transfer, and protects your (“you” or your”) personal and personally identifiable information, along with how you can contact Threecolts. to request amendment, modification, or deletion of your personal and personally identifiable information, when you use its services. This Privacy Notice is made and entered into by and between you (“you” or “your”), the user of one or more of these Services, and the relevant Threecolts entity providing the Services.

Except as where otherwise more specifically referenced in this Privacy Notice, each entity will generally be referred to as the “Company” or collectively as “Companies” or, where appropriate, as “we,” “our,” and “us.” This Privacy Notice is intended to provide you with the specific details about how each Company collects and processes your personal and personally identifiable information through your use of the Services. Each Company is a data processor of the information collected through the Services.

What does this Privacy Notice cover?

This Privacy Notice covers each Company’s collection, use, disclosure, transfer of, and protection of your personal and personally identifiable information. Three Colts Group, Inc. and its Companies are located in the United States of America and may store and process your personal and personally identifiable information in the United States of America. When you agree to this Privacy Notice and use the Services, you agree to the collection and processing of your personal and personally identifiable information in the United States of America and subject to the terms of this Privacy Notice.

Our Services may include links to websites or may include the use of analytics tools that are owned, operated, and maintained by third parties. Three Colts Group, Inc. and its Companies do not exercise control over the privacy practices such third party websites or analytics tools, and you are encouraged to review the privacy practices of all such third-party websites or analytics tools disclosed within this Privacy Notice.

Before using the Services or providing information to us, please carefully review this Privacy Notice. By using or accessing the Services, you agree that we may collect and use your personal and personally identifiable information in accordance with this Privacy Notice, as revised from time to time. Three Colts Group, Inc. and its Companies may modify, amend, replace, or suspend this Privacy Notice at any time. If you have any questions or suggestions regarding our Privacy Notice, or if your personal information is not accurate or complete, please contact us at:

Privacy Officer
Three Colts Group, Inc.
251 Little Falls Drive
Wilmington, Delaware 19808
United States of America
privacy@threecolts.com

By providing Three Colts Group, Inc. and its Companies with your personal or personally identifiable data and using the Services, you warrant that you are over the age of eighteen (18) or otherwise above the age of majority within your jurisdiction. If you are younger than eighteen (18) or the age of majority within your jurisdiction, please do not use the Services and please do not provide personal information to us.

What information do we collect?

When you use the Services, we may collect personal or personally identifiable information from you (“PII”). PII may include any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. It does not include anonymized data.

We may collect and process the following categories of PII about you:

• Identification and Contact Data. Identification and contact data includes data that you submit to us or authorize to be submitted to us through our Services, e-mail, or chat, such as your name, address, country, phone number, and email address, data that you voluntarily provide when submitting customer support requests or other communications to Threecolts or its Companies, and identification data that is collected automatically when you use our Services, such as data stored in persistent cookies when you login to our Services or analytics data that is collected from you when you use our Services. We collect and process identification and contact data to respond to your requests for products, services, or customer support, to operate our Services, to authenticate you as a user of our Services, to ensure that timely and relevant content is provided to you, to secure our Services, to ensure that our Services operate in a fast and efficient manner, and to maintain backups of our Services and any submissions that you may have made to them. Our lawful grounds for processing this data are (1) our legitimate business interests in administering and offering our Services, (2) to comply with legal obligations to which we are subject, (3) to utilize user data as necessary for the performance or administration of a contract, such as a contract related to the sale of our Services, and (5) your explicit consent. Where our collection and processing of your identification and contact data is based on your explicit consent, you have the right to revoke your consent at any time.
• Communication Data. Communication data includes any communication that you may send to us through the Services, email, live chat, chatbot, or social media. We process this data to communicate with you by email, live chat, direct message through a social media platform, or other means, to provide you with customer support, to record logs of our communication, and to store information to respond to legal claims. Our lawful ground for collecting and processing communication data is to respond to communications sent by you to us, to keep records of our communication, and to pursue or defend against legal claims.
• User Data. User data includes data that you voluntarily submit to us when you create a user account and data about how you use the Services, such as your name, address, country, phone number, and email address. This includes data stored in persistent cookies when you login to the Services and analytics data that is collected when you use the Services. We collect and process this data to operate the Services, to authenticate you as a user of the Services, to ensure that timely and relevant content is provided to you, to secure the Services, to ensure that the Services operate in a fast and efficient manner, and to maintain backups of the Services. Our lawful ground for processing this user data is its legitimate business interests in administering and offering the Services and to fulfill your orders for Services.
• Technical Data. Technical data includes data about your use of the Services, such as your IP address, your login data, your phone number, your mobile device model, your operating system, your geolocation, and your time zone. We may collect this data from your use of the Services and from advertising IDs, including from Meta’s pixel, TikTok’s pixel, Google Analytics IDs, and other analytics providers. A full list of our analytics providers and links to their respective privacy policies are provided below in this Privacy Notice. We processes this data to analyze your use of the Services, to route Services traffic, to administer and secure the Services, to provide location-relevant content, and to troubleshoot problems with the Services. Our lawful ground for collecting and processing this technical data is our legitimate interest in administering and offering the Services and to grow our business and marketing strategy.
• Marketing Data. Marketing data includes data about your preferences in receiving and interacting with our advertisements on third party platforms or content on the Services. We collect this data from your use of the Services and from advertising IDs created through advertising programs, such as Google Advertising IDs and Meta pixels. We do not connect advertising identifiers to persistent device identifiers, such as MAC addresses or mobile device IDs. Our lawful ground for collecting and processing this marketing data is our legitimate interests in administering and offering the Services and to grow our business and marketing strategy by providing advertisements, including remarketing advertisements, to you.
• Personally Sensitive Data. Personally sensitive data includes data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, union membership, or information about your health. We do not collect personally sensitive data. However, California law states that geolocation information may be considered sensitive personal information. We may collect your geolocation via your IP address, as otherwise specified in this Privacy Notice.

We will only use your PII for the purpose for which it was collected. If we need to use your PII for an unrelated new purpose, we will provide you with notice of this new use and will explain the lawful ground for such processing. We may process your PII without your knowledge or consent where required or permitted by law.

We do not use your PII to automatically make any decisions or to create an automated profile about you.

How do we collect this information?

We collect PII from you through a variety of different means:

• Direct Collection. We may collect PII from you when you purchase Services, register for Services, contact us through the Services, via live chat, social media, or otherwise, respond to a survey, participate in a contest, or when you opt-in to receive marketing emails, or mailings from us.
• Third Party Tracking Tools We use third party tracking tools, such as pixels, web beacons, and cookies, to automatically collect PII from you when you open, view, or click pages or links, emails, or advertisements. We disclose these third-party tracking tools below in this Privacy Notice in our disclosure of PII that we collect from third parties.
• Business Partners and Service Providers. We may, from time to time, obtain PII from our business partners or service providers. When we obtain PII from our business partners and service providers, we ensure that all such business partners and service providers have obtained consent from you to transfer all such PII to us for its intended uses.
• Social Media Networks and Other Platforms. We may obtain PII from you when you interact with our social media accounts or content posted on other third-party platforms, such as Facebook, X, or YouTube. For more information on how your PII may be disclosed by a particular social media network or platform, you are encouraged to review the privacy notices and policies of those platforms.
• Analytics Providers. We may also obtain PII from you through our use of third-party analytics providers, such as ActiveCampaign, Hubspot, Google Analytics, or Facebook. we may create user profiles based on PII obtained through our use of PII from third-party analytics providers to better understand your wants and needs as a customer. 

What information do we collect from third parties and how do we use it?

We may collect PII about you through cookies, web beacons, analytics trackers, and other technologies. This helps us understand how you use the Services, interact with our content and advertisements, and to understand any patterns that may be associated with your use of our Services. This aids us in developing or improving our Services, advertising, and marketing communications in response to your needs or wants.

We may use session or persistent cookies. Session cookies are only stored on your computer or mobile device during your use of our services and are automatically deleted when you close your web browser. Session cookies may be used to direct internet traffic to a server that is closer to you or to allow us to identify you as you move between pages of our Services. Persistent cookies are stored as a file on your computer or mobile device that remains on your computer or mobile device even after you close your web browser. Persistent cookies can be read by the website that created the cookie when you revisit it again. We may use persistent cookies to authenticate you when you return to our Services so that you do not have to login again or when we utilize Google Analytics or other analytics providers, which are intended to track the origin and behavior of traffic to our Services. We may use the following analytics providers, and you are directed to review their respective cookie policies and privacy notices: 

ActiveCampaign: https://www.activecampaign.com/legal/privacy-policy
Ahrefs: https://ahrefs.com/legal/privacy-policy
Fastly: https://www.fastly.com/privacy/
FullStory: https://www.fullstory.com/legal/privacy-policy/
Google Analytics: https://policies.google.com/privacy?hl=en-US
HotJar: https://www.hotjar.com/legal/policies/privacy/
HubSpot: https://legal.hubspot.com/privacy-policy
LinkedIn: https://www.linkedin.com/legal/privacy-policy
LogRocket: https://logrocket.com/privacy
Meta: https://www.facebook.com/policy/cookies/
Microsoft Clarity: https://privacy.microsoft.com/en-us/privacystatement
MixPanel: https://mixpanel.com/legal/privacy-policy
Plerdy: https://www.plerdy.com/privacy-policy/
Proof: https://www.proof.com/legal/privacy-policy
Segment: https://segment.com/docs/privacy/portal/
SEMRush: https://www.semrush.com/company/legal/privacy-policy/
Sprig: https://sprig.com/privacy-policy

You may opt-out of the use of these online tracking technologies by clicking the “Do Not Sell or Share My Personal Information” link associated with each third-party provider where available, discontinuing your use of our Services, or by downloading a browser addon, such as the Google Analytics Opt-Out Browser Add-on, to block third party collection and use of PII. You may also request that we delete any PII collected from you by contacting our Privacy Officer through the contact information contained within this Privacy Notice.

We do not yet recognize Global Privacy Control signals, but we strive to comply with any requests to opt out from the collection and use of PII. Should you wish to opt out from the collection and use of your PII, please contact our Privacy Officer through the contact information provided in this Privacy Notice.

How do we use your information for marketing communications?

As stated above, our lawful ground for sending you marketing communications is either consent or our legitimate business interests, such as to grow our business by advertising products to you. We may send you marketing communications if you have asked for information concerning our goods or services or if you have agreed to, and have not opted out from, receiving marketing communications. You may ask us to stop sending you marketing messages at any time by logging into our Services to adjust your marketing preferences within your user account (when available) or by following the opt-out link in any marketing message sent to you. If you opt out of receiving marketing communications, your opt-out does not extend to PII provided or processed for other purposes.

When do we disclose your information?

We may share your PII with the following parties:

• Service providers that provide us with information technology, software as a service, cloud storage, content delivery networks, advertising, marketing, or other administrative services;
• Other companies within the Threecolts group of companies that provide services to Threecolts
• Our accountants, auditors, insurers, or attorneys;
• Law enforcement agencies upon the receipt of a subpoena or court order or where necessary to protect our personnel or property; and
• Government bodies that require us to report our processing activities.

Under California law, the sharing of information with third party service providers, such as analytics providers, may be considered a transfer of PII. Though we do not sell your PII to third parties, we may transfer your PII to third party service providers for the purposes of analytics or using a data analysis or reporting tool.

We may also transfer PII to third parties when we sell, transfers, or merges any part of its business or assets. 

We require all third parties that receive a transfer of PII from us to maintain the same level of respect for the protection of PII as we do and we only allow third parties to process your personal data for the specific purposes listed in this Privacy Notice.

How do we handle international transfers of PII?

Your PII may be transferred to or processed by entities outside of the United States. As stated below, we adhere to the EU-US Data Privacy Framework Principles, and we may transfer data between the United States and the European Union consistent with the Data Privacy Framework Principles. When we do so, we enter into contracts, including standard contractual clauses provided by the European Commission or the United Kingdom’s Information Commissioner’s Office, with our third-party data processors that provide that such data may only be processed for the limited and specific purposes outlined in this Privacy Notice and consistent with the same level of protection provided under the Data Privacy Framework Principles. We require that our third-party processors must notify us if they can no longer meet the obligations of the Data Privacy Framework Principles. Upon such notification, we will require that our third-party processors must either remediate their failure to comply with the Data Privacy Framework Principles or cease their processing of PII.

How do we protect your information?

We implement a variety of security measures to maintain the safety of your personal information, such as the implementation of industry standard encryption, including when you subscribe to our Services. However, no security measures are impenetrable and there are always security risks. We will notify you and any regulatory body of any breach of your PII or our security measures when legally required to do so. We have put into place data security measures to protect your PII. We allow access to your PII only by employees and service providers who have a need to know or access your PII on our instructions.

Do we use cookies or other online tracking tools?

Yes, as stated above, we do use persistent and session cookies. We use cookies to help us remember and process your requests for Services, understand and save your preferences for future visits, and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

Do we use pixels or device fingerprinting technologies?

Yes, as stated above, we may implement and use third party pixels or device fingerprinting technologies to identify certain characteristics of users of our Services, such as operating system, screen size, browser name and version, language, and system date and time, for the purposes of fraud prevention and to prevent theft.

We may also use third party pixels or device fingerprinting technologies to improve our marketing efforts, including by assigning attribution to an advertising campaign through a specific third-party channel or to provide you with relevant advertisements, such as through remarketing campaigns. If you are located within the United Kingdom or the European Union, we only use third party pixels or fingerprinting technologies for these purposes after obtaining your prior consent.

For how long do we retain your PII?

We will only retain your PII for so long as necessary to fulfill the purposes for which it is collected under this Privacy Notice or for the purposes of satisfying any legal, accounting, or reporting requirements. With respect to identification and contact data, technical data, and marketing data, we may retain this data for so long as it is relevant to the uses disclosed in this Privacy Notice. We may retain user data and communications data for so long as you maintain a user account with us, and we may retain this data for longer periods where there is a need to retain this data to comply with our legal obligations, such as the preservation of electronic evidence or compliance with a preservation order.

Childrens’ Online Privacy Protection Act Compliance

We comply with the requirements of COPPA (Childrens’ Online Privacy Protection Act). We do not knowingly collect any information from anyone under 13 years of age, and our products and services are to individuals 13 years of age or older. If you believe that we have collected PII from someone under the age of 13, you are directed to notify us immediately at privacy@threecolts.com. 

YOUR PRIVACY CHOICES: Right of Access, Rectification, Correction, Erasure, Transfer, and Withdrawal

Under the law, you may have a right to request access to your PII for rectification, correction, erasure, transfer, or restriction, or to object to its processing or withdraw your consent. If you wish to exercise any of these rights, please contact our Privacy Officer as disclosed in this Privacy Notice.

You do not need to pay a fee to access your PII or to exercise your rights. However, we may charge a reasonable fee if your request is unreasonable or excessive.

To confirm your request, we may need to request specific information from you as a security measure to ensure that PII is not disclosed to an unauthorized third party. We will attempt to respond to all legitimate requests within thirty (30) days.

Rights of European Citizens

We adhere to the EU-U.S. Data Privacy Framework (“DPF”) Principles, including the DPF’s Supplemental Principles and comply with the Principles in handling all data from EU-citizens. We are subject to the enforcement powers of the United States Federal Trade Commission (“FTC”) in relation to its handling of PII.
If you are a European citizen, you are entitled to certain rights regarding the protection of your Personally Identifiable Information and Personal Data, which are subject to limitations set forth in the EU GDPR and its applicable case law. These rights are:

• The right to access and correct the information that we process about you;
• The right to transfer all or a part of the information collected about you to another data controller, where it is technically feasible;
• The right to the erasure of data concerning you, subject to our right of retention under the law;
• The right to object to the processing of Personally Identifiable Information and Personal Data where you dispute the accuracy of the data, the processing is not lawful, we no longer need the information for the purposes of processing, or you have raised an objection for personal reasons;
• The right to revoke your consent to data processing;
• The right to object to the processing of your Personally Identifiable Information and Personal Data for marketing purposes;
• The right to object to the processing of Personally Identifiable Information and Personal Data for direct marketing or for personal reasons that arise from your particular situation; and
• The right to file a complaint with a data protection authority.

To exercise these rights, you may opt out of receiving communications from us by unsubscribing to our e-mails, you can contact us by mail at the address listed in this Privacy Notice, or you can send an e-mail to privacy@threecolts.com. You do not need to pay a fee to exercise these rights, however, we reserve the right to charge a reasonable fee if your request is unreasonable or excessive. To confirm your request, we may need to request specific information from you as a security measure to ensure that personal data is not disclosed to an unauthorized third party. We will attempt to respond to all legitimate requests within thirty (30) days.

For further information regarding your privacy rights as a citizen of the EU, please visit the U.S. Department of Commerce’s website at https://www.commerce.gov/ and the DPF overview webpage at https://www.dataprivacyframework.gov/s/program-overview.

You can find a list of DPF certified organizations here: https://www.commerce.gov/ and the DPF overview webpage at https://www.dataprivacyframework.gov/s/

Beyond filing a complaint directly with us using the mechanisms described above, you may also file a complaint with a third-party, neutral arbitrator who will provide appropriate recourse free of charge. If you are looking for an alternative dispute resolution provider, please visit https://www.commerce.gov/ and the DPF overview webpage at https://www.jamsadr.com/eu-us-data-privacy-framework. JAMS is a US-based arbitration service provider. You are not required to use JAMS to arbitrate a dispute with us.

As a citizen of the EU you may, under certain conditions, invoke binding arbitration against us and we may be held liable in cases of onward data transfers to third parties as described more fully in DPF overview page linked above. We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We obtain these categories of PII directly from California residents when they complete forms through our Services, communicate with us, or provide it to us as a part of a transaction or inquiry concerning our Services. We also obtain these categories of PII indirectly from California residents while observing their actions on our Services and from third parties or service providers that they have authorized to receive and share PII.

California residents have a right to request that we disclose what PII we collect from you and whether, and how, we disclose or sell that PII. California residents may also request that we delete any personal information collected or maintained by us from you. 

California residents may also have the right to opt out of the sale of their personal information by contacting us or, where available, by clicking a link or icon associated with an advertisement. Specifically, this link or icon may state “Do Not Sell My Personal Information” or “Do Not Sell My Info.” By selecting this link or icon, you “Opt Out,” which means that you have opted out of the sale of your personal information as set forth in the California Consumer Privacy Act. However, even though you may have opted out, you may still see interest-based advertisements. To learn more about interest-based advertising across websites and additional opt-out choices, you can visit http://optout.aboutads.info. If you opt-out of the sale of your personal information but do not opt out of interest-based advertising more generally, you may still receive ads tailored to your interests based on PII that was not sold by us, personal information that was sold to downstream participants at least 90 days before you opted out, or personal information that was sold by other sources from which you have not opted out.

To submit a request for a list of the categories of personal information collected from you or to request that we delete your personal information, please email us at privacy@threecolts.com or send a letter to us at the following address:

Privacy Officer
Three Colts Group, Inc.
251 Little Falls Drive
Wilmington, Delaware 19808
United States of America
privacy@threecolts.com

To verify your request, we may request certain information from you to confirm that you are a user of our Services, such as your phone number, email address, city, state, or geographic location. You may also designate an authorized agent to make a request to us to disclose or delete your personal information. To do so, you must provide us with proof that the individual or business has been appointed as your agent, such by providing a signed power of attorney form, and provide accurate responses to any information requested by us that may be necessary to confirm that you are a user of our Services, such as your phone number, username, email address, city, state, or geographic location. California residents have a right not to receive discriminatory treatment by us for their exercise of these rights conferred under California law.

Colorado Residents

We do not conduct business in Colorado, control or process the personal data of 100,000 or more consumers during a calendar year, or derive revenue or receive a discount on the price of goods or services from the sale of personal data.

Connecticut Residents

During the preceding calendar year, we did not control or process the personal data of at least 100,000 consumers or derive more than 25% of our gross revenue from the sale of personal data. 

Montana Residents

We do not control or process the personal data of 50,000 or more Montana residents during a calendar year or derive over 25% of our revenues from the sale of personal data and control or processing of personal data of 25,000 or more Montana residents. Therefore, the Montana Consumer Data Privacy Act does not apply to our collection or use of PII.

Nevada Residents

If you are a resident of Nevada, you may provide notice to us to limit the sale of your PII to third parties for resale or licensing purposes. However, we do not sell your PII for such use. To notify us that you wish to limit the sale of your PII to third parties for resale or licensing purposes, you may send us an email to privacy@threecolts.com with the subject line, “Nevada Do Not Sell Request,” along with your name, address, and user account information.

Tennessee Residents

We do not control or process the personal information of 175,000 or more Tennessee consumers, or control or process the data of 25,000 consumers while deriving more than 50% of our gross revenue from the sale of personal information.

Texas Residents

We are considered a small business as defined by the Small Business Administration and, therefore, we are exempt from the Texas Data Privacy and Security Act. However, we generally collect and process PII only to the extent that it is adequate, relevant, and reasonably necessary for the purposes disclosed in this Privacy Notice. The categories of PII collected by us are disclosed within this Privacy Notice, and Texas residents may request, free of charge, information of the PII collected from them twice annually.

Utah Residents

We do not control or process the PII of 100,000 or more consumers. Therefore, the Utah Consumer Privacy Act does not apply to our collection and use of PII.

Virginia Residents

We do not control or process the personal data of at least 100,000 Virginia residents or control or process the personal data of at least 25,000 Virginia residents and derive more than 50% of our gross revenue from the sale of personal data. For these reasons, the Virginia Consumer Data Protection Act (VCDPA) does not apply to our collection and use of PII.

Third Party Links

Our Services may include links to third party websites and applications. By clicking on third party links, you may allow third parties to collect or share data about you. We do not control these third-party links and you are advised to review their respective privacy policies.

Responding to Do Not Track Signals

You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. Our Services are not currently set up to respond to browser do-not-track signals because there is no consensus within the advertising industry as to what “do not track” means in this context, but you can configure your browser settings to reject all cookies or prompt you before a cookie is set.

Changes to our Privacy Notice

Whenever we change our Privacy Notice, we will post those changes to this Privacy Notice through our Service and other places that we deem appropriate. Your use of our Service following these changes indicates your consent to the practices described in the revised Privacy Notice.

Contacting Us

If you have any questions about this Privacy Notice or the manner by which we collect or use Personal Information about you, email us at privacy@threecolts.com.