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EFFECTIVE JULY 1, 2020
We respect the privacy of our users and want to ensure that every measure is taken to protect
your personal information in the event we need or are required to collect and store it. This
Policy is for that purpose
SA Co.™ is a division of TDS Management, Inc. (“TDS Management”), which is located in the
(“Policy”) describes TDS Management and all of its divisions, which include SA Co.™, Alpha
Defense, and Alpha Defense Gear’s (collectively, “us” or “we” or “our”), privacy practices and
how data is collected and processed by us in connection with the use of our websites
(www.safishing.com, and www.alphadefensegear.com), applications, and other platforms
(collectively, the “Platforms”). This Policy is also intended to explain the conditions under
which we collect, use, and disclose personal and other data in connection with the Platforms, and
your rights in relation to that information.
By visiting and/or using the Platforms, you consent to our collection, use and transfer of your
personal and other information for processing in the United States as described in this Policy.
The personal and other information that we collect about you is controlled by us in the United
States. If you reside or are otherwise located outside of the United States, please note that
the information and data we collect will be processed and stored in the United States. Data
protection and privacy laws, rules, and regulations in the United States may differ from
those in the jurisdiction in which you are located, and may not have the same level of
protection as the laws, rules and regulations in the country or territory in which you reside
or are located. Your use of the Platforms and the providing of information to us
constitutes your consent to the transfer to and processing of your personal information in
the United States unless otherwise stated within this Policy.
The Policy outlines the legal basis on which we collect
and use your personal and other information and provides all other necessary information in
accordance with the General Data Protection Regulation (the “GDPR”).
Data Controller: TDS Management, Inc. is the data controller and is responsible for the
collection, use, disclosure, dissemination, retention, and protection of your personal information
in accordance with this Policy and applicable law.
“Personal information” is information we can use to identify you, directly or indirectly, with or
without additional information. This includes, but is not necessarily limited to, your name, email
address, mailing address, telephone number, credit card number, other payment information, and
certain “cookies.” See our “Cookies Policy” for more information on cookies.
We collect both personal information and non-personal information about Platform users. For
purposes of this Policy, “non-personal information” is information that we cannot directly
associate with a specific person without the aid of additional information. When we combine
non-personal information with personal information, we treat all of the combined information as
We collect, use, disclose and disseminate personal information in accordance with this Policy in
order to, without necessarily any limitation, operate and improve the Platforms; market and
advertise our services and products; improve our business and the level of service we strive to
offer our customers; and to comply with legal requirements.
The following are the ways in which we may collect your personal information. The purposes
for these uses are discussed in the section that follows, called “How we use the personal and
non-personal information that we collect.”
1. Registration: In order to subscribe to certain services or use many features offered on our
Platforms, you may be required to register by providing certain personal information such as
your name, email address, phone number, date of birth, shipping address, and/or payment
2. Purchases: If you purchase a product or service from us, we require certain personal
information from you on our order form. This personal information may include your name,
email address, shipping address, and payment information.
3. Social Media: Certain of our Platforms are connected to social media platforms such as
Facebook, Twitter and Instagram. These social media platforms allow users to submit personal
information that may be accessible to other users and/or the general public. You may be required
to first register with the social media platform by providing information such as an email
address, display name, and password. Registrants also may choose to voluntarily provide
additional information, including an avatar image, a biography, and/or information about their
location on the social media platforms. And, of course, registrants may disclose personal and
other information through their posted content.
4. Feedback: Our online contact form also contains a “message” field through which you
may submit additional personal information.
5. Surveys, Contests, and Promotions: From time to time, we may ask Platform users to
participate in surveys, contests, or promotions. Taking part in such surveys, contests or
promotions may require you to submit personal information, such as your name, address, email
address, and date of birth.
6. Tracking technologies: When you use the Platforms, we automatically receive and record
certain information from your computer (or other device) and your browser, which may include
your IP address and domain name, the pages you visit or the features you use on the Platforms,
the date and time of your visit, the files that you download, the URLs from the websites you visit
before and after navigating to the Platforms, your software and hardware attributes (including
device IDs), your general geographic location (e.g., your city, state, or metropolitan region), web
beacons, device, IDs, advertising IDs, and certain cookie information. To obtain such
information, we may use web logs or applications that recognize your computer or device and
gather information about its online activity. Click here to read our “Cookies Policy”
7. Third-party online tracking and behavioral advertising: We also may partner with certain
third parties to collect, analyze, and use some of the personal information described in this
section. For example, we may allow third parties to set cookies or use web beacons on the
Platforms or in email communications from us. This information may be used for a variety of
purposes, including online behavioral advertising, as discussed below (see the section entitled
:“How we share personal and non-personal information with third parties”).
We use the information that we collect as set forth above for many reasons. We may use it: (1) to
respond to your questions or requests concerning the Platforms or other services offered by us;
(2) to fulfill the terms of any agreement you have with us; (3) to fulfill your requests for our
services and orders for products or otherwise complete a transaction that you initiate; (4) to send
you information about our products and/or services, the status of any orders, and other topics that
are likely to be of interest to you, including newsletters, updates, or other communications; (5) to
verify billing information; (6) to deliver confirmations, account information, notifications, goods
or products, service-related announcements, and similar operational communications; (7) to
improve or personalize your user experience on the Platforms; (8) to improve the quality of our
products and services; (9) to comply with legal and/or regulatory requirements; and (10) to
manage our business.
We use the non-personal information that we collect for such purposes as: (1) counting and
recognizing users of the Platforms; (2) analyzing users’ demographics, interests, and behavior,
including how they use the Platforms and various Platform features; (3) improving the Platforms
and enhancing users’ experiences with the Platforms; (4) researching and creating new products
and services or improving our existing products and services; (5) enabling additional website and
application analytics and research concerning the Platforms; (6) and managing our business. We
may link non-personal information gathered using certain tracking technologies such as cookies
and web beacons with personal information. But in that event, we will treat the combined
information as personal information.
If you choose to use our referral service to tell a friend about our products or services, we will
ask you for your friend’s name and email address. We will automatically send your friend a
one-time email inviting him or her to visit the Platforms. This personal information may be used
to track the success of our referral program. Your friend may contact us at
[email protected] to request that we remove this information from our
We share your personal information and non-personal information with other parties for many
reasons, as described above in the prior section of this Policy, and in the following ways.
Related Businesses: We may disclose personal information within our different divisions (i.e.,
SA Co.™ and Alpha Defense), and to any affiliates or companies that are owned or controlled by
us to improve the Platforms, the products and services that we offer, for marking and advertising
purposes, and in general to improve our business.
Service Providers: We may disclose personal information to third parties that provide us with
certain services in an effort to improve the performance of the Platforms, the products and
services that we offer, and in general to improve our business.
Advertising and Marketing: We may disclose personal information to third parties that provide
advertising and marketing services on our behalf and on behalf of our service providers, to the
extent appropriate. The Platforms also enable third-party tracking mechanisms to collect your
non-personal information for use in online behavioral advertising. For example, third parties may
use the fact that you visited the Platforms to target online ads for our services to you on websites
or services not owned or controlled by us. In addition, our third-party advertising networks might
use information about your use of the Platforms to help target advertisements based on your
online behavior in general. Please see our “Cookies Policy” for more information on this
Analytics: We may disclose personal information to certain third parties to help us analyze,
audit, research, and improve the Platforms and the products and services that we offer.
Fulfill legal obligations: We also may share your personal and/or non-personal information with
other third parties when necessary to fulfill your requests for services; to complete a transaction
that you initiate; and to meet the terms of any agreement that you have with us or our business
Third-party platforms: Our Platforms may enable you to directly share personal information
with third party platforms (like Facebook, Instagram, Google) through links to the third-party
platforms. If you choose to share your personal information with these third party platforms, you
may disclose your personal information not just to those third-party platforms, but also to their
users and the public more generally. Because these third-party platforms are not operated by us,
we are not responsible for the content or practices of those platforms. The collection, use,
dissemination and disclosure of your personal and non-personal information by those third party
platforms, and their plug-ins, will be subject to the policies of the third party platforms, not this
Policy. Further, certain features of our Platforms make it possible for you to share comments or
feedback publicly with all other users of the Platforms. Please take care when using these
features of the Platforms
Legal Purposes: We also may use or share your personal or non-personal information with third
parties when we believe, in our sole discretion, that doing so is necessary:
● to comply with applicable law or a court order, subpoena, or other legal process;
● to investigate, prevent, or take action regarding illegal activities, suspected fraud,
violations of our terms and conditions, or situations involving threats to our property or the
property or physical safety of any person or third party;
● to establish, protect, or exercise our legal rights or defend against legal claims; or
● to facilitate the actual or proposed financing, securitization, insuring, sale, assignment,
bankruptcy, or other disposal of all or part of our business or assets.
Security: We use commercially reasonable physical, electronic, and procedural safeguards to
protect your personal information against loss or unauthorized access, use, modification, or
deletion. When you enter sensitive information (such as a credit card number and/or your social
security number) on our registration or order forms, we encrypt that information using secure
socket layer technology (SSL). However, no security program is foolproof, and thus we cannot
guarantee the absolute security of your personal or other information.
This section applies if you reside outside the United States. It is possible that more than one legal
basis may apply. As previously outlined in this Policy, there are several reasons why we may
collect and process your personal information. For purposes of this policy, TDS Management,
Inc. is the controller of the personal information you provide to us.
Your consent may not be required depending on the circumstances under which your personal
information is collected and/or used. Instances where consent is not required include, but are not
Performance of a contract: To perform our contractual obligations to you, including registration,
processing, fulfilling, and shipping orders, contacting you about your order, your use of the
Platforms, where we need to provide your personal information to within our different divisions
and affiliated companies or companies that are owned or controlled by us and to our service
providers, where we need to collect personal information from third party sources and when you
access third party products and services, where we collect data from third parties or
publicly-available sources, or to combine data.
Legal obligations: To comply with all laws, statutes, codes, rules, regulations, subpoenas, court
orders, legal processes, or any other legal obligation.
Legitimate Interests: To operate our business, and provide the products and services offered on
the Platforms, other than in performing our contractual obligations owed to you, for our
“legitimate interests.” Legitimate interests include, but are not necessarily limited to the
1. To communicate with you regarding our products, services, Platforms and any changes in
the policies outlined herein, and to respond to any communications and/or requests you send to
us for any reason.
2. To provide you with promotional messages and surveys when you register and otherwise
sign up to receive promotional messages and take part in surveys.
3. To comply with our legal obligations and defend our rights and the rights of others,
including providing your personal information to the appropriate authorities to assist in any legal
investigation into possible unlawful activity.
4. To improve, enhance, or otherwise change our products, services, and the Platforms, and
for our own internal purposes geared towards improving our business. This includes research,
analytics, monitoring, customer service, risk management, and our own internal administrative
5. To enforce this Policy or agreements with third parties.
6. In connection with the sale or transfer of all or part of our business.
When Consent is Required
We may need to obtain your consent in order to collect and process your personal information,
which may be provided in a number of ways as outlined below. Certain instances where we may
request your consent include, but are not necessarily limited to:
1. To contact you by email or other electronic means about other offers, products,
promotions, or services that we think may be of interest to you and for other marketing purposes.
2. To share your personal information with certain third parties that want to offer certain
goods, services, offers, promotions, and/or programs. In this case, you will need to contact the
third party in accordance with their policies about withdrawing consent.
3. To use your personal information for research purposes and to contact you to see if you
are interested in taking part in any market research campaigns or programs.
4. To use your information to contact you and to connect with us or other third parties on
5. To use your personal information for special offers, events, sweepstakes, and other
Withdrawing your consent to use your personal information may be accomplished at any time for
any reason. We will not collect or use your personal information in the future once you
withdraw your consent, to the extent your consent was necessary in order to collect or use such
information. You may withdraw your consent by “opting out” of the purposes for which you
had previously authorized us to collect and use your personal information by sending an email to
[email protected] with “opt out” in the subject line. You may click on the
“unsubscribe” link in any email that contains one, such as promotional emails (which emails will
also have instructions for opting out of that type of communication in the future).You may also reply with “Stop” or “Opt Out” to any SMS or text message you receive after signing up to receive promotional/marketing SMS/text messages from us”
We will remove you from our e-mailing and SMS/text messaging lists as soon as possible after receiving notification from
you that you have chosen to “opt out.”
Please refer to our “Cookies Policy” by clicking here with respect to withdrawing any other form
Any other questions that concern your desire to withdraw consent should be sent to
In addition – change “TDS Management, Inc.” to “TDS Management, LLC” throughout the policy.
Your personal information will be retained by us as long as is necessary pursuant to this Policy.
We will delete your personal information when it is no longer needed or required to be
maintained by us pursuant to this Policy, and when appropriate and authorized by applicable law.
You also have the right “to be forgotten” and having all of your personal information deleted by
submitting a request to us at [email protected] to delete your personal
information, provided we are permitted to do so by applicable law. To the extent permitted, we
will endeavor to delete your personal information as soon as possible upon receipt of your
If you have any questions regarding the deletion or retention of your personal information, please
contact us at [email protected].
We reserve the right to amend this policy at any time. We will post all changes to this policy on
this website, so you should review the policy periodically. Any such amendments to this policy
may apply to information we collect in the future as well as any information we obtained prior to
such amendment. If we make a material change to this policy, we will provide appropriate notice
as required by law. Your continued use of our website following the posting of changes
constitutes your acceptance of such changes.
If you have any questions or comments about this Policy, please do not hesitate to contact us at:
TDS Management, Inc.
Attn: Privacy Compliance
1140 Holland Drive
Boca Raton, FL 33487
E-mail: [email protected]
solely to all visitors, users, and others who reside in the State of California (“consumers” or
“you”). This notice is adopted to comply with the California Consumer Privacy Act of 2018
(CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
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”).
In particular, we have collected the following categories of personal information from its
consumers within the last twelve (12) months:
We obtain the categories of personal information listed above from the following categories of
● Directly from you from forms you complete on our website or products you purchase
● Indirectly from you. For example, from observing your actions on our Website via
● From social media platforms such as Facebook, Twitter and Instagram. These social
media platforms allow users to submit personal information that may be accessible to
other users and/or the general public. You may be required to first register with the social
media platform by providing information such as an email address, display name, and
password. Registrants also may choose to voluntarily provide additional information,
including an avatar image, a biography, and/or information about their location on the
social media platforms. And, of course, registrants may disclose personal and other
information through their posted content.
We may use or disclose the personal information we collect for one or more of the following
● To fulfill or meet the reason you provided the information. For example, if you share
your name and contact information to ask a question about our products or services, we
will use that personal information to respond to your inquiry. If you provide your
personal information 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, support, personalize, and develop our website, products, and services.
● To create, maintain, customize, and secure your account with us.
● To process your requests, purchases, transactions, and payments and prevent
● To provide you with support and to respond to your inquiries, including to investigate
and address your concerns and monitor and improve our responses.
● To personalize your website experience and to deliver content and product and service
offerings relevant to your interests, including targeted offers and ads through our website,
third-party sites, and via email or text message (with your consent, where required by
● To help maintain the safety, security, and integrity of our website, products and services,
databases and other technology assets, and business.
● For testing, research, analysis, and product development, including to develop and
improve our website, products, and services.
● To respond to law enforcement requests and as required by applicable law, court order, or
● As described to you when collecting your personal information or as otherwise set forth
in the CCPA.
● 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 information held by us
about our website users and/or consumers is among the assets transferred.
We will not collect additional categories of personal information or use the personal information
we collected for materially different, unrelated, or incompatible purposes without providing you
We may disclose your personal information to a third party for a business purpose. When we
disclose personal information for a business purpose, we enter a contract that describes the
purpose and requires the recipient to both keep that personal information confidential and not use
it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
● Service providers.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the information identified in the INFORMATION WE COLLECT section above for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
Sales of Personal Information
We have not sold any personal information in the preceding twelve (12) months, nor do we have
any intention to sell any personal information without first notifying you and complying with
The CCPA provides consumers) with specific rights regarding their personal information. This
section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
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. Once we receive and confirm your
verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we
will disclose to you:
● The categories of personal information we collected about you.
● The categories of sources for 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 (also called a data
● If we disclosed your personal information for a business purpose, identifying the personal
information categories that each category of recipient obtained.
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. Once we receive and confirm your
verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we
will delete (and direct our service providers to delete) your personal information from our
records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service
1. Complete the transaction for which we collected the personal information, 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal
activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech
rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §
1546 et. seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based
on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the
context in which you provided it.
To exercise the access, data portability, and deletion rights described above, please submit a
verifiable consumer request to us by either:
● Emailing us at [email protected]
● Clicking on the following link and completing the Data Request form:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer
request related to your personal information. You may also make a verifiable consumer request
on behalf of your minor child. To designate an authorized agent, click on the following link and
complete the Authorized Agent form.
You may only make a verifiable consumer request for access or data portability twice within a
12-month period. Your request must:
● Provide sufficient information that allows us to reasonably verify you are the person
about whom we collected personal information or an authorized representative, which
may include your name, address, email address, order number and /or the last 4 digits of
the credit card or debit number used for an associated purchase; 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 information if we cannot verify
your identity or authority to make the request and confirm the personal information relates to
Making a verifiable consumer request does not require you to create an account with us. We will
only use personal information provided in a verifiable consumer request to verify the requestor’s
identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its
receipt. We will inform you if we need more time, and the reasons and extension period in
writing if we require more time.
If you have an account with us, we will deliver our written response to that account. If you do
not have an account with us, we will deliver our written response by mail or electronically, at
Any disclosures we provide will only cover the 12-month period preceding the verifiable
consumer request’s receipt. 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 information 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.
We do not currently sell your personal information. Notwithstanding, you have the right to
direct us to not sell your personal information at any time (the “right to opt-out”). To exercise
the right to opt-out, you (or your authorized representative) may submit a request to us by filing
out our Do Not Sell My Personal Information form:
Opt Out Form
You do not need to create an account with us to exercise your opt-out rights. We will only use
personal information provided in an opt-out request to review and comply with the request.
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.
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
information to third parties for their direct marketing purposes. To make such a request, please
send an email to [email protected]
If you have any questions or comments about this notice, the ways in which TDS Management
collects and uses your information, your choices and rights regarding such use, or wish to
exercise your rights under California law, please do not hesitate to contact us at:
TDS Management, Inc.
Attn: Privacy Compliance
1140 Holland Drive
Boca Raton, FL 33487
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