Privacy Policy

Last modified: May 24, 2023

Introduction

Turnkey Merchandise Programs, a Michigan L.L.C., (the "Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.

This privacy policy (the “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website https://www.peepsandcompany.com/ (our "Website") and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Privacy Policy applies to information, including Personal Data (defined herein), we collect:

On this Website.
In email, text, and other electronic messages between you and this Website.
Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

It does not apply to information collected by:

us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or
any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on our Website.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see “Changes to Our Privacy Policy” section herein). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information, including Personal Data to or on the Website. We do not knowingly collect information, including Personal Data (defined herein) from children under 13 years of age. If you are under 13 years of age, do not use or provide any information on this Website or on or through any of its features, do not make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn that we have collected or received Personal Data (defined herein) from a child under 13 years of age without verification of parental consent, we will delete that Personal Data. If you believe we might have any information from or about a child under 13 years of age, please contact us at dataprivacy@tmpcompany.com.

Information, including Personal Data, You Provide to Us.

The information, including Personal Data, we collect may include:

Information, including Personal Data that you provide by filling in forms on our Website. This may include information provided at the time of registering to use our Website, subscribing to our service, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, or any third party; and when you report a problem with our Website;
Records and copies of your correspondence (including email addresses), if you contact us;
Details of transactions you may carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

Information, Including Personal Data, We Collect About You and How We Collect It

We collect several types of information, including Personal Data, including information:

relating to an identified or identifiable individual (the “Data Subject”) who can be identified, directly or indirectly, in particular by reference to an identifier such as, but not limited to, a name, email address, postal address, telephone number or an online identifier (the “Personal Data”); and
about your Internet connection, the equipment you use to access our Website and usage details.

We collect this information, including Personal Data:

Directly from you when you provide it to us;
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website;
Information about your computer and Internet connection, including your IP address, operating system and browser type.

The information we collect automatically is statistical data and may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns;
Store information about your preferences, allowing us to customize our Website according to your individual interests;
Speed up your searches;
Recognize you when you return to our Website.

Technologies we use for this automatic data, including Personal Data, collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Information, Including Personal Data

We use information, including Personal Data, that we collect about you or that you provide to us, including any Personal Data:

To present our Website and its contents to you;
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Data to respond to your inquiry. If you provide your Personal Data to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns;
To provide you with information, products or services that you request from us;
To fulfill any other purpose for which you provide it;
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
To notify you about changes to our Website or any products or services we offer or provide through it;
In any other way we may describe when you provide the information;
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by us about Data Subjects is among the assets transferred;
For any other purpose with your consent.

We may also use your information, including Personal Data, to contact you about our own and third parties' goods and services that may be of interest to you. If you do not want us to use your information, including Personal Data, in this way, please adjust your user preferences in your account profile and opt out by unsubscribing therefrom.

Disclosure of Your Personal Data

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect, or you provide as described in this Privacy Policy:

To our subsidiaries and affiliates;
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them;
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding;
To fulfill the purpose for which you provide it;
For any other purpose disclosed by us when you provide the information;
With your consent.

We may also disclose your Personal Data:

To comply with any court order, law or legal process, including responding to any government or regulatory request;
To enforce or apply agreements, including for billing and collection purposes;
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

In addition, we will not send you e-mails that you have not agreed to receive, nor will we provide your information to third parties. We may periodically send you e-mail announcing news, updates and event information, and, if you choose to supply your postal address, you can receive mailings from us as well.

Choices About How We Use and Disclose Your Personal Data

We strive to provide you with choices regarding Personal Data you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Processing Personal Data According to the CCPA

Additionally, this section of the Policy applies solely to all visitors, users, and others who reside in the State of California (collectively, "consumers" or "you"). We have adopted this notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Policy.

(a) Information We Collect

The description of Information We Collect is included in the Information, Including Personal Data, We Collect About You and How We Collect It section of this Policy.

For this CCPA Section, Personal Data shall not include:

Publicly available information from government records;
Deidentified or aggregated consumer information; and
Information excluded from the CCPA's scope.

In particular, the Company has collected the following categories of Personal Data from consumers within the last twelve (12) months on with regards to information submitted or purchases made on https://www.peepsandcompany.com/:

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Yes
B. Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	Yes
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other Personal Data.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

(b) Use of Personal Data

The Use of Personal Data is addressed in the How We Use Your Information, Including Personal Data section of this Policy.

(c) Sharing Personal Data

We do not sell Personal Data.

We may disclose your Personal Data for business purpose. In the preceding twelve (12) months, Company has disclosed the following categories of Personal Data to the categories of third parties indicated in the chart below.

Personal Data Category	Business Purpose Disclosures
A: Identifiers	None
B: California Customer Records Personal Data categories.	None
C: Protected classification characteristics under California or federal law.	N/A
D: Commercial information.	None
E: Biometric information.	N/A
F: Internet or other similar network activity.	None
G: Geolocation data.	None
H: Sensory data.	N/A
I: Professional or employment-related information.	N/A
J: Non-public education information.	N/A
K: Inferences drawn from other Personal Data.	N/A

(d) Your Rights and Choices

The CCPA provides consumers (i.e. California residents) with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months (the "right to know"). Once we receive your request and confirm your, we will disclose to you:

The categories of Personal Data we collected about you;
The categories of sources for the Personal Data we collected about you;
Our business or commercial purpose for collecting or selling that Personal Data;
The categories of third parties with whom we share that Personal Data;
If we sold or disclosed your Personal Data for a business purpose, two separate lists disclosing:
sales, identifying the Personal Data categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained;
The specific pieces of Personal Data we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Data not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request to the address indicated in the Contact Information section of this Policy.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Data.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.

We will only use Personal Data provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

(e) Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services;
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Data's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

(f) Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email using contact information provided in this Policy.

You Rights Provided by other State Privacy Laws

State consumer privacy laws, other than the CCPA and the "Shine the Light" law, such as Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

Confirm whether we process their Personal Data.
Access and delete certain Personal Data.
Data portability.
Opt-out of Personal Data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

Correct inaccuracies in their Personal Data, taking into account the information's nature processing purpose.
Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please contact us at dataprivacy@epiinc.com. The appeal procedure from a decision regarding a consumer rights request is addressed in each of the above state laws.

Nevada provides its residents with a limited right to opt-out of certain Personal Data sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: dataprivacy@epiinc.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

Processing Personal Data According to the GDPR

Additionally, if the processing of your Personal Data falls within the scope of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (the “GDPR”), then such processing shall also be performed in accordance with GDPR requirements. Therefore, in addition to the above terms, Company provides you with the following information:

The contact information for the Company Data Privacy Officer is provided in the Contact Information section of this Policy;
Personal Data is processed only for the express purposes set forth in this Policy;
Personal Data may be transferred to processors located around the world;
You are entitled to:
- Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it;
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate Personal Data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
- Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
- Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
- Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
You may at any time lodge a complaint with a supervisory authority located in the European Union having jurisdiction over processing; and
Company does not perform automated decision-making, including profiling.

Accessing and Correcting Your Personal Data

You may also send us an email at dataprivacy@epiinc.com to request access to, correct or delete any Personal Data that you have provided to us. We may not accommodate a request to change your Personal Data if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration and disclosure. All Personal Data you provide to us is stored on our secure servers behind firewalls.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security thereof transmitted to our Website. Any transmission of personal information, including Personal Data, is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Data Retention

The Company will not retain your Personal Data longer than is necessary for the purpose it was collected.

Changes to Our Privacy Policy

It is our Privacy Policy to post any changes we make to our Policy on this page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us at: dataprivacy@tmpcompany.com.