Threecolts LLC provides cloud-based services for businesses that sell on the Amazon.com platform (collectively, the “Services”). This Privacy Policy (“Privacy Policy”) is made and entered into by and between you (“You” or “Your”), the user of one or more of these Services, and the relevant entity providing the Services, which are:

1. In the case of SellerBench, 3CG SELLERBENCH LLC, a Delaware limited liability company (“SellerBench”);
2. In the case of OldStreetMedia, Old Street Media LLC, a Delaware limited liability company (“Old Street Media”);
3. In the case of TacticalArbitrage, 3CG TACTICALARBITRAGE LLC, a Delaware limited liability company (“TacticalArbitrage”);
4. In the case of Bindwise, 3CG BINDWISE LLC, a Delaware limited liability company (“Bindwise”);
5. In the case of HotShp, 3CG HOTSHP LLC, a Delaware limited liability company (“HotShp”);
6. In the case of RefundSniper, 3CG REFUND SNIPER LLC, a Delaware limited liability company (“RefundSniper”);
7. In the case of ChannelReply, 3CG CHANNELREPLY LLC, a Delaware limited liability company (“ChannelReply”).
8. In the case of ScoutIQ, 3CG SCOUTIQ LLC, a Delaware limited liability company (“ScoutIQ”).
9. In the case of OnSite, 3CG ONSITE LLC, a Delaware limited liability company (“OnSite”).
10. In the case of FeedbackWhiz, 3CG FEEDBACKWHIZ LLC, a Delaware limited liability company (“FeedbackWhiz”).
11. In the case of Threecolts, THREECOLTS LLC, a Delaware limited liability company (“Threecolts”).
12. In the case of InventoryLab, 3CG INVENTORYLAB LLC, a Delaware limited liability company (“InventoryLab”).
13. In the case of ExportYourStore, 3CG EXPORTYOURSTORE LLC, a Delaware limited liability company (“ExportYourStore”).
14. In the case of DataSpark, 3CG DATASPARK LLC, a Delaware limited liability company (“DataSpark”).
15. In the case of Hemi , 3CG HEMI LLC , a Delaware limited liability company (“Hemi").
16. In the case of SelleLocker , 3CG SELLERLOCKER LLC , a Delaware limited liability company (“SelleLocker").
17. In the case of SellerRunning , 3CG SELLERRUNNING LLC , a Delaware limited liability company (“SellerRunning").
18. In the case of CamelCamelCamel , 3CG CAMEL LLC , a Delaware limited liability company (“CamelCamelCamel").
19. In the case of SmartRepricer , SMART REPRICER LLC , a Delaware limited liability company (“SmartRepricer").

Except as where otherwise more specifically referenced in this Privacy Policy, each entity will generally be referred to as the “Company.” This Privacy Policy 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.
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The Company is located in the United States and it may transfer Your personal or personally identifiable information to countries outside of the European Union. Many of the Company’s third-party service providers are located within the United States and their processing of personal or personally identifiable information will involve a transfer of data outside of the European Union. Whenever personal data is transferred outside of the European Union, the Company does its best to ensure a similar degree of security and data privacy by requiring that its service providers and its foreign parents or subsidiaries adopt standard contractual clauses covering the transfer of this data.
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Additionally, the Company takes measures that supplement transfer tools, such as standard contractual clauses, to ensure compliance with the level of protection of personal data in the European Union. For example, when the Company receives an expedited circumstances request, a subpoena, a warrant, or a court order to disclose personal or personally identifiable information from law enforcement or regulators in the United States, the Company carefully validates these requests, including by reviewing the legality of such request, subpoena, warrant, or court order and challenging them if there are grounds under the law to do so before any personal or personally identifiable information is disclosed.

Before using the Services or providing information to us, please carefully review this Privacy Policy. By using or accessing the Services, You agree that the Company may collect and use Your information in accordance with this Privacy Policy, as revised from time to time. If You have any questions or suggestions regarding our Privacy Policy, or if Your personal information is not accurate or complete, please contact us at:

Threecolts LLC
16192 Coastal Highway
Lewes, DE 19958
‍privacy@threecolts.com
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By providing Company 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 the Company.

When You use the Services, the Company may collect personal or personally identifiable information from You (“PII”). PII may include any information capable of identifying an individual, but it does not include anonymized data.
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The Company may collect and process the following categories of PII about You:

The Company may also request Your consent to collect and process data You provide to us. You can always revoke Your consent by changing Your account settings or emailing us with Your opt out request at: privacy@threecolts.com.
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The Company will only use Your PII for the purpose for which it was collected. In the event that the Company needs to use Your PII for an unrelated new purpose, they Company will provide You with notice of this new use and will explain the lawful ground for such processing or ask for Your consent. The Company may process Your PII without Your knowledge or consent where required or permitted by law.
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The Company does not use Your PII to automatically make any decisions related to creditworthiness.

• Third-party service providers that provide the Company with information technology or other administrative services;
• The Company’s accountants, auditors, insurers, or attorneys;
• Upon receipt of a duly authorized subpoena or court order;
• To protect itself, its employees and independent contractors, and its property; and
• Government bodies that require the Company to report its processing activities.

• The right to know which personal information is being collected;
• The right to know if personal information is being sold or shared, and to whom;
• The right to object to the sale of personal information;
• The right to access ones’ own personal information; and
• The right to equal service and price for consumers who exercise their privacy rights

• The Company collects the following categories of personal information ("Personal Information”), as defined in the CCPA:
  • Identifiers, such as Your real name, address, IP address, e-mail address, and similar identifiers;
  • Personal information, such as Your name, telephone number, and billing and transaction information;
  • Commercial information, such as records of services that You have purchased or considered purchasing from the Company;
  • Internet or other electronic network activity, including Your interaction with the Services or the Company’s advertisements;
  • Geolocation, such as Your approximate physical location derived from Your IP address; and
  • Professional or employment-related information, such as Your employer or job title.
• The Company shall not retain, use, disclose, or otherwise process Your Personal Information for any purpose other than for performing the Services, or as otherwise permitted by the CCPA and shall return or delete Your Personal Information at the conclusion of performance of the Services, or sooner if directed by You. The Company shall follow all of Your lawful instructions regarding the return or destruction of Your Personal Information. Upon request from You, the Company shall disclose to You which categories of Your Personal Information the Company has collected, used, or shared with third parties within the twelve (12) month period preceding the request. Notwithstanding the foregoing, the Company may combine Personal Information received from one or more entities to which it provides similar services to the extent necessary to detect data security incidents or to protect against fraudulent or illegal activity.
• Upon a verifiable consumer request, the Company will delete Your Personal Information from its records, and direct all of its service providers who possess Your Personal Information, if any, to also delete such Personal Information, provided that the Company shall not comply with a deletion request if the Company needs the Personal Information for any of the following reasons: (i) providing goods or services to the consumer, (ii) detecting and resolving issues relating to security or functionality, (iii) complying with legal obligations, (iv) conducting research in public interest, (v) exercising free speech or ensuring another’s exercise of free speech or (vi) using the information for internal purposes that the consumer might expect.
• The Company shall not “sell” (as defined in the CCPA) any of Your Personal Information. The Company does not collect information on children under the age of 13.
• The Company shall assist You in fulfilling its obligations under the CCPA to respond to individual requests related to Your Personal Information about them, including by promptly fulfilling requests to access or delete relevant Personal Information in The Company’s possession. If the Company receives a request to know, or a request to delete, from a consumer regarding Personal Information that the Company collects or maintains, and does not comply with the request, it shall explain the basis for the denial. The Company shall also inform the consumer that it should submit the request directly to You and, when feasible, and provide the consumer with Your contact information.
• The Company shall enter into written agreements with each third-party subcontractor, if any, that processes Your Personal Information that obligate the subcontractor to comply with terms that are at least as restrictive as those imposed on The Company under this Privacy Policy, including the prohibition on the sale of Your Personal Information. 
• To exercise Your consumer rights, please submit a request to privacy@threecolts.com. 

• The right to access and correct the information that the Company processes 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 the Company’s rights of retention under the law;
• The right to object to the processing of PII where You dispute the accuracy of the data, the processing is not lawful, the Company no longer needs 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 PII for marketing purposes;
• The right to object to the processing of PII 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 either edit and update Your PII within Your User Account, opt out of receiving communications from the Company by unsubscribing to its e-mails, or by sending an e-mail to privacy@threecolts.com. You do not need to pay a fee to exercise these rights, however, the Company reserves the right to charge a reasonable fee if Your request is unreasonable or excessive. To confirm Your request, the Company 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.