BESTOP TUFFY LLC (TUFFY SECURITY PRODUCTS) PRIVACY POLICY

Privacy Policy

PRIVACY POLICY

Bestop Premium Accessories Group and its affiliates and subsidiaries (collectively, “BPAG,” “us,” “we,” or “our”) has prepared this Privacy Policy (“Privacy Policy”) to describe our online and offline practices regarding the personal information that BPAG collects, uses, and shares. This Privacy Policy applies to the websites owned and controlled by BPAG that link to this Privacy Policy (each, a “Site”), our mobile applications (each, an “Application”), our email communications, and our related products and services (together with the Site and Application, the “Platform”).

BPAG reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy. Your continued use of the Platform following posting of changes constitutes your acceptance of such changes.

  1. COLLECTION OF PERSONAL INFORMATION
    • Personal Information. The following are categories (with non-exhaustive examples) of personal information we may collect about you:
Categories Examples
A. Individual Identifiers and Demographic Information A real name, alias, postal address, unique personal identifier, phone number, online identifier, Internet Protocol address, email address, account name, social media information, shipping and billing addresses, general location information (such as your zip code or city), or other similar identifiers.
B. Sensitive Personal Information Financial or credit/debit card account information, such as payment details collected during the purchase process.
C. Geolocation Data Precise physical location or movements, if you choose to share that information when using the App.
D. Commercial Information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. May also include your communications with us and your reviews, posts, blog comments, photos, questions, and other materials posted by you to the Platform or feedback and other content you provide on our social media sites.
E. Internet or Network Activity Browsing history, search history, information on an individual’s interaction with a website, application, or advertisement.
F. Inferences Drawn from Personal Information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

 

Personal information does not include:

  • Publicly Available Data – Publicly available information from government records.
  • Deidentified or Aggregate Information – “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which BPAG has implemented technical safeguards and business processes that prohibit reidentification of the individual. “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device. BPAG may use and share Deidentified Information and Aggregate Information in its discretion.
  • Excluded Information – Certain laws require separate privacy notices or are exempt from general personal information privacy policy disclosure requirements. Such laws include health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or clinical trial data; the Gramm-Leach-Bliley Act (GLBA); Fair Credit Reporting Act (FCRA); and the Driver’s Privacy Protection Act of 1994.
    • Sources of Personal Information. We obtain the categories of personal information listed above on or through our Platform from the following categories of sources:
  • Personal Information You Provide. BPAG collects personal information when you voluntarily submit it to us. For example, we may collect or receive personal information from you if you create an account on the Platform; edit registration information; purchase a product; sign up to receive promotional communications; use or access products and services available through the Platform; participate in one of our promotional sweepstakes, contests, or surveys; post a review; submit a request to our customer service team; interact with our social media pages; or otherwise interact with us or other users through the Platform. BPAG also collects any user generated content posted by you to the Platform.
  • Automatically Collected Personal Information. In addition to personal information that we may receive directly from you, BPAG indirectly collects other information from you automatically through the Platform. For example, we receive personal information from users when a user visits and navigates to our Platform on any device; installs and uses the Application; receives our emails; or enables location-based features on the Application. We, our service providers, and our advertising partners may also collect personal information about you over time and across different websites, apps, and devices. Third parties also collect personal information this way on our Platform. BPAG collects some personal information automatically using cookies and other online tracking technologies, including software development kits in our Application. See our Cookie Policy for more information.
  • Personal Information Obtained from Third Parties. In addition to the personal information that we collect from you directly and automatically, BPAG may receive personal information about you from other third party sources. For example, we receive personal information from our business partners, social media sites, third party marketing firms, or companies that provide personal information to supplement what we already know about you. We may merge or combine such personal information with the personal information we collect from you directly or automatically. We may also receive information about you if someone refers you to us or wishes to purchase something on our site for you.

 

  1. USE OF PERSONAL INFORMATION

BPAG’s primary purpose in collecting personal information is to provide the products and services that you request on the Platform. BPAG may also use personal information for various purposes, including without limitation to:

  • To Provide and Operate Our Products and Services. This could include fulfilling your requests for products or services, establishing, and maintaining your account, identifying you as a user on the system, processing purchases or other transactions, facilitating deliveries, and processing your returns. For example, if you share your personal information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. This could also include communicating with you about the Platform, including by sending you announcements, updates, security alerts, and support and administrative messages, providing customer support and maintenance for the Platform, enabling security features of the Platform, and using your location to identify pick-up locations (in some jurisdictions).
  • To Improve Our Products and Services. We may use personal information to understand and analyze the usage trends and preferences of our users to make our Platform, products, and services better, diagnose technical issues, and develop new features and functionality. We also use it to determine what products and services to offer and to improve site layout and navigation.
  • To Create Deidentified Information and Aggregate Information. We may also use your personal information to create Aggregated Information, Deidentified Information, or other anonymous data records from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Platform and promote our business.
  • Direct Marketing of Our Products or Services. We may use our personal information to provide you with information about BPAG products, services, or promotions.
  • Other Advertising. We and our advertising partners may use cookies or other online tracking technologies to provide customized advertisements, content, and information and to monitor and analyze the effectiveness of marketing activities. These might be third party offers we or our partners think you might find interesting. These communications may come in the form of interest-based advertising using information gathered across multiple websites, devices, or other platforms.
  • Compliance, Fraud Prevention, and Safety. We use personal information to maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, business, and other Users. For example, we may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements; enforce the terms and conditions that govern the Platform; and protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber-attacks and identity theft.
  • As Required by Law. We use personal information to respond to requests from law enforcement and as required by applicable law, court order, legal process, or government investigation.
  • With Your Consent. In some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as where required by law.
  1. SHARING OF PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy or at the time of collection, BPAG may share your personal information in the following circumstances:

  • Related Companies. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us), including without limitation other companies in the Bestop Premium Accessories Group.
  • Business Transactions. If we sell all or part of its business or make a sale or transfer of assets or is otherwise involved in a merger, financing, acquisition, dissolution, or business transfer, we may transfer, share, or disclose all or a portion of your personal information to a third party as part of that transaction, including at the negotiation stage, or in the event of an insolvency, bankruptcy, or receivership.
  • Legal Compliance. We may disclose personal information to law enforcement, government authorities, and others in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other Users; or to prevent a violation of our Terms of Service.
  • Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the Platform. Among other things service providers may help us perform website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or any other use set out in this Privacy Policy.
  • Interest-Based Advertising Partners. We participate in interest-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Platform so that we and other parties can provide advertising about products and services tailored to your interest, and/or use hashed customer lists that we share with them to deliver ads to you and similar users on their platforms. That advertising may appear either on our Platform, or on other websites, applications, and services.
  • Partner or Client Offerings. We may jointly offer events, promotions, or any other product or service offerings with third party partners or our clients. The personal information that you submit through an event, sweepstakes, promotion, or other product or service offering may be combined and transmitted with the registration information related to your account. Third party partners or clients may collect information directly from you, which may be combined with personal information disclosed by us. If you decide to request, enter into, or participate in an event, sweepstakes, promotion, or other product or service offering that is offered by us and identified as a joint effort with a third-party partner or client, the information that you provide may be shared with us and with that third party.
  • Social Networking and Third Party Platforms. The Platform may offer you the ability to share your personal information through a social networking website (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button), or to use your account information from a third-party platform like Google to register for an Account. The use of some integrated tools may enable you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.
  • Public Forum and Messaging. The Platform may provide you with the opportunity to post comments, messages, or reviews in a public forum. If you decide to submit personal information at these locations, that information will be available to other users of the Platform.
  • Referrals. Users may recommend other contacts to join the Platform by providing their contact information or selecting friends from a social networking site. Users may also provide information about other users of the Platform such as reviews of the services or products that he or she received, booking or scheduling information, or reference information.
  • Professional Advisors. We may share your personal information with our professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

 

  1. SECURITY OF PERSONAL INFORMATION

We take commercially reasonable steps to protect personal information, including efforts to facilitate PCI compliance in connection with the payment information we or our payment processors collect. Please note, no method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.

  1. TEXT MESSAGES

If you opt-in, we may send you text messages about our products and services. You understand that you are not required to provide this consent as a condition of receiving information about our products and services. You also understand that you may opt-out of receiving text messages from us at any time, either by texting the word “STOP” in reply to any text message from us using the mobile device that is receiving the messages, or by contacting us at 1-800-845-3567. You are responsible for obtaining the data network access and mobile device necessary to send and receive any text messages. Your mobile network’s data and messaging rates and fees may apply if you send or receive text messages.

  1. YOUR CHOICES

You can make the following choices regarding your personal information:

  • Access to Your Personal Information. You may request access to your personal information by contacting us as described below. We will grant you reasonable access to the data that we have about you as required by law.

 

  • Changes to Your Personal Information. We rely on you to update and correct the personal information contained in your Account. Note that we may keep historical information in our backup files as permitted by law. If our Platform does not permit you to update or correct certain personal information, please contact us as described below.

 

  • Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request that we delete your personal information by contacting us contacting us as described below. We will grant a request to delete information as required by law, but you should note that in many situations we must keep some of your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.

 

  1. OPTING OUT

You can make the following choices to opt out of certain activities regarding your personal information:

  • Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our Platform, as well as targeted offers from third parties. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may still send you service-related communications, such as those about your Account, to fulfill orders for products and service you have requested, or deliver notifications directly to you through the Platform.

 

  • Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Platform so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Platform, or on other websites and online services. If you wish to limit third parties’ collection of information about your use of our Platform, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. Users of our Applications may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE PLATFORM. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

 

  • Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you do not want to be “tracked” online. At this time we do not modify your experience based upon whether such a signal is broadcast.

 

  1. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

BPAG and its affiliates and subsidiaries are based in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in the Terms of Service related to the use of and access to the Platform.

If you are located in the European Union, European Economic Area, or United Kingdom, please see the section below titled “Notice to European Users” for additional information regarding your personal information.

  1. CHILDREN

The Platform is not intended for use by children under sixteen (16) years of age. If we learn that we have collected personal information from a child under sixteen (16) without the consent of the child’s parent or guardian as required by law, we will delete it.

  1. CONTACTING US

If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us by calling 1-800-845-3567, emailing us at [email protected], or writing to us at the address below:

Bestop Premium Accessories Group

Attn: Privacy Agent

333 Centennial Parkway, Suite B
Louisville, CO 80027

 

  1. RESIDENTS OF CALIFORNIA

The following section applies only to residents of California. It describes how we collect, use, and share personal information of California residents when we act as a “business” as defined under the California Consumer Privacy Act of 2018 (“CCPA”), and their rights with respect to their personal information. For purposes of this section, “personal information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. In some cases we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.

  • Notice to California Residents. We describe:
  • the categories of personal information we may have collected about you in the preceding 12 months and the sources from which we collect this information in the section above called “COLLECTION OF PERSONAL INFORMATION”;
  • the business and commercial purposes for which we collect this information in the section above called “USE OF PERSONAL INFORMATION”; and
  • the categories of third parties to whom we disclose this information in the section above called “SHARING OF PERSONAL INFORMATION”.

BPAG must also disclose whether the following categories of personal information are disclosed for a “business purpose” or “valuable consideration” as those terms are defined under California law. The CCPA also calls this latter category a “sale” of personal information. Note that while a category below may be marked, that does not necessarily mean that we have personal information in that category about you. In the preceding twelve months, we have disclosed the following categories of Personal Information in the manner described:

Category Information is Disclosed for a Business Purpose Information is Disclosed for Valuable Consideration
A. Individual Identifiers and Demographic Information Yes Yes
B. Sensitive Personal Information Yes No
C. Geolocation Data Yes No
D. Commercial Information Yes Yes
E. Internet or Network Activity Yes Yes
F. Inferences Drawn from Personal Information Yes Yes

 

  • Your California Privacy Rights. The CCPA provides California residents with the rights listed below.
  • Access. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months, including:
    • The categories of personal information we collected about you.
    • The categories of sources of the personal information we collected about you.
    • Our business or commercial purpose for collecting or selling that personal information.
    • The categories of third parties with whom we share that personal information.
    • The specific pieces of personal information we collected about you.
  • Deletion. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
  • Opt-Out of Sales. If we “sell” your personal information as described above, you can opt out.
  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our products and services.

Please note, these rights are not absolute and in some cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

 

  • How to Exercise Your California Privacy Rights. Access and Deletion Rights. To exercise the access and deletion rights described above, please submit a request to us and provide the information we request that is required to verify your request by:
  • Right to Opt-Out of the “Sale” of Personal Information. Under California law, some of the data we share with our affiliate advertising partners may qualify as a “sale” as defined under the CCPA. To exercise your right to opt-out of such “sale”, please:

When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. You may also designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide the requester’s proof of identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify your request.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

We try to respond to all legitimate requests within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.

  • Notice of Disclosure for Direct Marketing. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with BPAG and/or BPAG brands are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit your request to the address listed in the section titled “CONTACTING US” above.

 

  1. NOTICE TO EUROPEAN USERS

The information provided in this “Notice to European Users” section applies only to individuals in the European Union, the European Economic Area, or the United Kingdom (collectively, “Europe”).

  • Personal Information. Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
  • Controller. The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is the BPAG entity named on the part of the Platform that you use or access, or from whom you purchase an item.
  • Lawful basis for processing. BPAG is required to inform you of the lawful basis of our processing of your personal information, which are described in the table below. If you have questions about the lawful basis of how we process your personal information, contact us at the address listed in the section titled “CONTACTING US” below.
Processing Purpose (for more information, see the corresponding descriptions above in the section titled “USE OF PERSONAL INFORMATION”) Lawful Basis
• To Provide and Operate Our Products and Services Processing is necessary for the performance of a contract. You are subject to a contract with us and we need to use your personal information to provide products and services.
• To Improve Our Products and Services.

• To Create Deidentified Information and Aggregate Information.

• Compliance, Fraud Prevention, and Safety.

 

Processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent, or we are otherwise required to perform a contract or by law).
• Direct Marketing of Our Products or Services. Processing activities constitute our legitimate interests. In some jurisdictions, processing may instead be based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated on the Platform.
• Other Advertising.

• With Your Consent.

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated on the Platform.
• As Required by Law. Processing is necessary to comply with our legal obligations.

 

We will use your personal information only for the purposes for which we collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider deidentification, aggregation, and anonymization of personal information to be compatible with the purposes listed above and in your interest, because the deidentification, aggregation, and anonymization of such information reduces the likelihood of improper disclosure of that information.

 

PLEASE NOTE WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR CONSENT, IN COMPLIANCE WITH THE ABOVE RULES, WHERE THIS IS REQUIRED OR PERMITTED BY LAW.

 

  • Sensitive Information. Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Platform, or otherwise to us.

 

  • Retention. BPAG retains your personal information:
    • For so long as your Account is active or as needed to provide you with the Platform or to fulfill our contractual obligations;
    • As necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; and
    • For so long as is necessary for the purposes for which we collected such personal information.

 

  • Your Rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
    • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
    • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
    • Correct. Update or correct inaccuracies in your personal information.
    • Restrict. Restrict the processing of your personal information.
    • Object. Object to our reliance on our lawful basis as the basis of our processing of your personal information that impacts your rights.
    • Delete. Delete your personal information.

When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested.

If you are a resident of Europe and would like to exercise any of these rights, please submit your request to the address listed in the section titled “CONTACTING US” above. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection authority in your jurisdiction. You can find your data protection regulator here.

  • Cross-Border Data Transfer. If we transfer your personal information out of Europe to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so.

Bestop, Inc. and its subsidiaries, including Aluminess, Baja Designs, Bestop, Bullring, MGP Calipers, Offroad Source, PRP Seats, Softopper, Speedstrap, SPOD, Status Racing, and Tuffy Security Products, comply with the US-EU and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of transferred from the European Union and Switzerland to the United States. Bestop, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. Bestop, Inc.’s participation in the Privacy Shield applies to all personal data that is subject to this policy and is received from the European Union, European Economic Area, and Switzerland. Bestop, Inc. is responsible for the processing of such personal data it receives under the Privacy Shield Frameworks and subsequent transfers to a third party acting as an agent on its behalf. In particular, Bestop, Inc. remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Bestop, Inc. proves that it is not responsible for the event giving rise to the damage. The Federal Trade Commission (FTC) has jurisdiction over Bestop, Inc.’s compliance with the Privacy Shield. In compliance with the Privacy Shield Principles, Bestop commits to resolve complaints about your privacy and our collection or use of your personal information. EU and Swiss individuals with questions or concerns about the use of their personal data, or with questions about how you can access your data, should contact us at [email protected] If a customer’s question or concern cannot be satisfied through this process Bestop, Inc. and Bestop, Inc. have further committed to refer unresolved privacy complaints under the Privacy Shield to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Bestop, Inc., EU and Swiss individuals may bring a complaint before the BBB Online Privacy Shield dispute process. Information about how to file a complaint before the BBB Privacy Shield program can be found at: www.bbb.org/EU-privacy-shield/for-eu-consumers/. The BBB services are provided at no cost to EU and Swiss individuals. Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

 

Effective Date: February 11, 2021