Privacy Policy

BOLTON

PRIVACY POLICY

Introduction

BOD Group, Inc. and each of their affiliates, and subsidiaries (“Bolton” “us” “we” or “our”) takes the privacy of our users (“you” or “yours”) information very seriously. This privacy policy (“Privacy Policy”) applies solely to information collected by Bolton and its subsidiaries and its affiliates, and explains:

the information we collect about you;
how that information may be used;
with whom the information may be shared;
how you may update the information you provide us;
how you may contact us; and
your choices about the information.

By using our websites including, but not limited to, boltonusa.com (collectively, “Websites”), using any of our mobile applications, calling customer service, engaging with us on social media, interacting with us in any way, or utilizing any of our services (together with the Websites, the “Services”), you consent to be bound by this Privacy Policy in respect of the information collected about you via the Services.

What Information Do We Collect?

This Privacy Policy primarily concerns Personal Information, which deals with individuals, rather than organizations or businesses. “Personal Information” uniquely identifies an individual, household or device, or can identify an individual, household or device by combining it with other data. It includes email addresses, phone numbers and other information associated with the individual, household or device. As described below, we may collect Personal Information about you in connection with our Services and your use of the Websites. The legal name and definition of personal information differs from jurisdiction to jurisdiction. Bolton will not use, sell or share Personal Information other than as described in this Privacy Policy.

We collect Personal Information from you through your engagement with our Services in a variety of ways, including but not limited to in connection with requests for services, the creation of a personal user account, requests for support, when you subscribe to our newsletters, forms that you complete and any other information or material you may post to our Websites or social media pages, and your submission of information to us, including, on any of our Websites. From time to time, we may provide you the opportunity to participate voluntary activities, including through the Websites or other Services. We may request Personal Information from you, along with other information, in order for you to participate in these activities. Participation in these activities is completely voluntary; you may elect not to disclose your Personal Information by not participating in the activity.

Personal Information collected by us may include your:

Name
Email address
Phone number
Mailing address
User-created username and password

We also collect and store general usage metrics of the Services, email communication history with Bolton, and other information associated with you or your organization, as well as other information that may or may not specifically identify you. The information collected through the Services may be stored at servers, computers, or other media located in the United States.

We may obtain information about you from third-party sources, such as Google, Apple or your employer, when applicable. This information may be utilized, analyzed, and/or compared with information that Bolton has collected from you or that you have submitted to the Services. If Bolton obtains information from third-party sources, you agree that your sole legal remedy for any harm associated with that information is against the third-party that provided the information to us, and that you will not assert any cause of action, claim or demand against us other than requesting we delete any erroneous information.

For the avoidance of doubt, Bolton shall be entitled to collect anonymous and/or aggregated data across its various products and services provided that no individual natural person can be identified from such data (“Aggregate Data”). The Aggregate Data will be used for various purposes, including without limitation to analyze behavior, trends, and website interaction, and to improve, and enhance our services and for other development, creation of new features, diagnostic and corrective purposes in connection with our services. Bolton shall own all rights, title and interest in and to the Aggregate Data and this is not considered personal data.

Information Collection Technology; Cookie Declaration

For each visitor to our Websites, we may use various technologies, including “cookies” to automatically gather certain information pursuant to your use of the Websites, and from your electronic device about your activities using the Websites. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services

We may collect and store non-personally identifying information through cookies and third parties to profile user activity and preferences. Technical and specification information about your device and settings may be collected when you use the Website. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, the content of previously accepted “cookies” from us, and clickstream data. We collect and store this information on an individual basis and in combined form. We also collect both user-specific and aggregate information on what pages visitors access or visit.

We use cookies to compile aggregate data about site traffic and site interactions to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.

If you turn cookies off, some of the features that make your user experience more efficient may not function properly. Turning off the cookies may affect the user’s experience, making the user’s experience less efficient and some of the site features may not function properly.

Google Analytics

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users and may be found at: https://support.google.com/adwordspolicy/answer/1316548?hl=en

We use Google AdSense Advertising on our website.

Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

Google Display Network Impression Reporting
Demographics and Interests Reporting

We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

Opting out:

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

Web Beacons

Our Services may contain web beacons (also known as “clear gifs”) or similar technologies that gather non-personally identifiable information about your use of our Services. Such technology may also be contained in e-mail messages from us that allow us to determine whether messages have been accessed. The purpose of our use of this technology is so that we may analyze the effectiveness of the quality of our Services and for other internal uses which may include marketing efforts.

How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?

It is important to note that we allow third-party behavioral tracking.

Permissions

The following section only applies if you use one of our mobile software applications (the “Software”). The Software requires certain permissions on your mobile device in order to work as intended. You can either allow or deny the Software access to the permissions. In some cases, it is necessary for you to grant the Software permissions to take full advantage of features or functionality of the Software. If you disallow some or all permissions, the Software may not function properly. Some of the permissions needed may include access to your device’s: camera; calendar; location; phone; sensor; SMS; and storage. Additional permissions may be requested as new features may be added in the future.

How Do We Use Your Information?

We may use and share your information for any legally permissible purpose. We may match, use, and share any of the information we collect from you to any personally identifiable information we obtain through third parties. The ways we may use or share information that we collect about you include:

providing you with use of the Websites and Services;
providing you with products or services, whether from Bolton, or any related organizations, entities, or affiliates;
providing you with customized content and other services;
providing technical or customer support;
performing research and analysis to gauge the use of the Websites and Services;
communicating with you by e-mail, postal mail, telephone, text message, and/or mobile devices about products or services that may be of interest to you from Bolton, any affiliates, sponsors, or other third-parties;
enforcing, this Privacy Policy, other Bolton posted policies, enforce Bolton agreements, or otherwise manage its business;
to administer the working relationship with you/your employer;
where we have another legitimate interest in doing so;
in connection with any possible sale merger or restructuring of all or any part of our business or assets; and
performing functions as otherwise described to you at the time of collection.

To perform certain services on your behalf, we may publish certain information that you provide. You agree that any testimonial feedback, stories, posts, interactions, or other comments provided by you to Bolton through any form of communication including but not limited to through the Websites, becomes the sole and exclusive property of Bolton and that such information may be used for any legally permissible purpose, including, but not limited to marketing and advertising our Services.

You acknowledge and agree that, unless otherwise prohibited by law, Bolton may use and disclose your personal and non-personal information to public or private third-parties: (i) for inspection by law enforcement officials (including in the case of potential criminal activity); (ii) to respond to cease and desist letters, arbitration proceedings, legal actions and suits, criminal and civil subpoenas, any court orders; (iii) to enforce or apply the terms of this Privacy Policy or any other agreement between us; and (iv) to protect our, our users, and others’ rights, property, or safety whether during or after the term of your use of our Services.

Except as otherwise provided in this Privacy Policy, we do not rent, sell or share any personal information we collect to any third parties.

Unless otherwise provided in this Privacy Policy, we shall not disclose Personal Information you submit to us except (i) with affiliates, licensees, subsidiaries, and successors, (ii) when we have your permission, or (iii) as necessary to:

To our affiliates as permitted by law;
To third parties who provide information technology services such as website hosting, computer systems maintenance, or data security and privacy services;
To our partners, affiliates, vendors, or others who help us operate the Services or assess your interest or satisfaction with the Services, our organization, or our products, provided they have contractually agreed to adhere to this Privacy Policy. Also, to your employer in connection with your orders on their behalf; or
To comply with our legal obligations, enforce this Privacy Policy, any other Bolton agreements, or otherwise to protect the rights, property or safety of our users and business partners.

In addition, we may share aggregate and sell, non-individual information, incapable of identifying a particular person, with third parties for any lawful purposes.

COPPA Disclaimer Regarding Children Under 13

In accordance with COPPA (Children’s Online Privacy Protection Act), our Websites do not collect any information from anyone under 13 years of age. Our Services and Websites are all directed to people who are at least 18 years old or older. Bolton reserves the right to suspend the accounts and other access to the Services for individuals who Bolton determines are aged 17 years old or younger.

For California Residents

We collect 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 consumer, household, or device (“personal information“). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.

In particular, we collected the following categories of personal information from consumers within the last twelve (12) months:

Implied Consent Under CASL

Persons in Canada who contact us and/or provide their telephone number or email address are providing implied consent under Canada’s Anti-Spam Legislation (CASL) for us and our affiliate companies to send them electronic marketing communications under CASL. See here for contact information for us and our affiliate companies, as required under CASL. If you do not wish to give this consent under CASL, please do not provide your telephone number or email address. You may cancel this implied consent at any time by opting out as described in this Privacy Policy.

International Users

The Websites are hosted in the United States and are governed by the laws of the State of Maryland of the United States. We recognize that it is possible for you to obtain access to the Websites from any jurisdiction in the world, but we have no practical ability to prevent such access. The Websites has been designed to comply with the laws of the United States – if any material on the Websites, or your use of the Websites, is contrary to the laws of the place where you are when you access the Websites, then the Websites is not intended for you, and we ask you not to use the Websites. You are responsible for informing yourself of the laws of your jurisdiction and complying with them. If you are using the Websites from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our databases are operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Websites, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in our Privacy Policy.

Notice to EU and UK Residents: Bolton will not process your user information without a lawful basis to do so; as such bases are defined in Article 6 of the GDPR and, with respect to UK residents, in Chapter 2 of the UK GDPR. References in this Privacy Policy to the UK GDPR shall apply only to individuals who are covered by the provisions of the UK GDPR (generally residents of the United Kingdom). In general, we will process your user information on the legal bases of consent, contract (if you have entered into an agreement with us and such processing is a necessary part thereof), or legal obligation (as noted above). We may also process certain user information on the basis of the following legitimate interests, provided that such interests are not overridden by your privacy rights and interests: delivering and continuing to develop and improve the Websites, learning from your behavior on the Websites (e.g., analyzing traffic) to better serve you and other Websites users, helping us modify or enhance the Websites and their content, receiving insight as to what users do (and don’t) like about our Websites or aspects thereof, and providing a stable, consistent, and secure user experience in connection with the Websites. For specific processing of personal data we collect from you and not covered by the above, we will inform you whether the provision of personal data is statutory or required to enter a contract and whether it is an obligation to provide the personal data and possible consequences if you choose not to. Bolton agrees to use standard contractual clauses as a safeguard for transferring your user information.

You Have the Following Rights Under the GDPR and UK GDPR:

Right to access: You have the right to request information about the personal data we hold on you at any time. You can contact us and we will provide you with your personal data via e-mail.
Right to portability: Whenever we process your personal data by automated means based on your consent or based on an agreement you have the right to get a copy of your data in a structured, commonly used and machine-readable format transferred to you or to another party. This only includes the personal data you have submitted to us.
Right to rectification: You have the right to request rectification of your personal data if it is incorrect, including the right to have incomplete personal data completed. If you have an account you can edit your personal data under your account and membership pages.
Right to erasure: You have the right to erase any personal data processed by us at any time except for the following situations:
you have an ongoing matter with us.
you have an open order which has not yet been shipped or partially shipped.
you have an unsettled debt with us, regardless of the payment method.
if you are suspected or have misused our services within the last four years.
your debt has been sold to a third party within the last three years or one year for deceased customers.
your credit application has been rejected within the last three months.
if you have made any purchase, we will keep your personal data in connection to your transaction for bookkeeping rules.
Right to object to processing based on legitimate interest: You have the right to object to processing of your personal data that you believe is not based on our legitimate interest. We will suspend processing of the personal data unless we can demonstrate a legitimate ground for the process which overrides your interest and rights or due to legal claims.
Right to object to direct marketing (if applicable): You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes. You can opt out from direct marketing by the following means:
following the instruction in each marketing mails.
by editing the settings of your account.
Right to restriction: You have the right to request that we restrict the processing of your personal data under the following circumstances:
if you object to a processing based on our legitimate interest, we shall suspend all processing of such data pending the verification of the legitimate interest.
if you claim that your personal data is incorrect, we will restrict all processing of such data pending the verification of the accuracy of the personal data.
if the processing is unlawful you can oppose the erasure of personal data and instead request the restriction of the use of your personal data instead.
if we no longer need the personal data but it is required for you to make of defending legal claims.

How can you exercise your rights?: Please contact marketing@boltonusa.com.

Right to complain with a supervisory Authority: If you believe we are processing your personal data in an incorrect way you can contact us. You also have the right to turn in a complaint to a supervisory authority, having jurisdiction.

Opt Out Procedures

You may contact Bolton to review, update and correct your Personal Information.

If you do not wish to receive promotional emails or other marketing communications from us, please let us know by using the opt-out response device that can be found at the bottom of every email we deliver or by contacting us as provided below. At places on our Websites where you give us your personal information, you may opt out of receiving those communications. Although you can opt not to receive promotional messages, we reserve the right to send you informational email messages about any user account you establish on our Websites, or notices regarding the Websites, as permitted.

To help us process your request, please include sufficient information for us to identify you in our records. We may need to verify your identity before providing you with Personal Information or updating it in our system.

Information Security

We follow generally accepted industry standards to protect the personal information submitted to us, and to protect against loss, misuse, or alteration of your information. When you provide personally identifying information, we encrypt transmissions involving such information using secure protocols.

We do not use vulnerability scanning and/or scanning to PCI standards.

We only provide articles and information. We never ask for credit card numbers.

We use regular Malware Scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.

Please note however, that while we use commercially reasonable methods to protect your personal information, we cannot guarantee its absolute security. Therefore, although we take reasonable steps to secure your information, we cannot and do not promise or warrant that your information will always remain secure.

External Links and Third-Party Privacy Practices

Bolton cannot guarantee or verify the contents of any externally linked website. You should therefore note you click on external links at your own risk and Bolton cannot be held liable for any damages or implications caused by visiting any external links. This Privacy Policy does not cover any third party’s use or handling of your information once it is shared. Instead, the privacy policy of the third party will govern. We encourage you to visit the websites of those third parties and fully read and understand their privacy policies. Some of these entities will have different privacy terms than we do, and their servers may be located outside the United States.

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Contact Us

If at any time you would like to unsubscribe from receiving future emails, you can email us at marketing@boltonusa.com and we will promptly remove you from ALL correspondence.

If there are any questions regarding this privacy policy, you may contact us using the information below.www.boltonusa.com

1 W. Pennsylvania Ave, Ste 600

Towson, MD 21204
info@boltonusa.com
410-547-0500

On any email or postal letter that you send, please include “Privacy” in the subject line.

Changes to this Policy

This Privacy Policy may be updated from time to time. We reserve the right to modify the Policy at any time without notice, so please review the Privacy Policy frequently. When changes are made to this Privacy Policy, we will revise the “last updated” date at the start of this Privacy Policy. Your continued use of our Websites or Services after we have posted any policy changes indicates your agreement to the changes unless you notify us otherwise.