Privacy Policy

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 United States at 1140 Holland Drive, Suite 6, Boca Raton, Florida 33487. This Privacy Policy (“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.

EUROPEAN UNION RESIDENTS:

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:

“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 personal information.

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.

How Personal Information is collected:

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 information.
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”).

How we use the personal and non-personal information that we collect:

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 database.

How we share personal and non-personal information with third parties:

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 subject.

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 partners.

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.

SMS Abandoned Cart Disclosure: The website uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS.

Third-party Data Sharing: The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

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.

Our Legal Basis for Processing Your Personal 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 limited to:

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 following:

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 purposes.
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 social media.
5. To use your personal information for special offers, events, sweepstakes, and other promotions.

Withdrawal of Consent:

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 of consent.

Any other questions that concern your desire to withdraw consent should be sent to [email protected].

In addition – change “TDS Management, Inc.” to “TDS Management, LLC” throughout the policy.

Data Retention:

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 request.

If you have any questions regarding the deletion or retention of your personal information, please contact us at [email protected].

Changes to this Policy:

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.

Questions:

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]

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS:

This section supplements the information contained in our Privacy Policy above and applies 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.

Information We Collect:

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 sources:

• Directly from you from forms you complete on our website or products you purchase from us.
• Indirectly from you. For example, from observing your actions on our Website via cookies.
• 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.

Use of Personal Information:

We may use or disclose the personal information we collect for one or more of the following purposes:

• 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 transactional fraud.
• 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 law).
• 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 governmental regulations.
• 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 notice.

Sharing Personal Information:

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:

• Service providers.

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 applicable law.

Your Rights and Choices:

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 portability request).
• If we disclosed your personal information for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights:

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 provider(s) to:

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.

Exercising Access, Data Portability, and Deletion Rights:

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:

https://safishing.com/pages/sa-privacy-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.

https://safishing.com/pages/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 you.

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.

Response Timing and Format:

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 your option.

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.

Personal Information Sales Opt-Out and Opt-In Rights:

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

https://safishing.com/pages/sa-privacy-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.

Non-Discrimination:

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

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

Other California Privacy Rights:

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

Contact Information:

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

E-mail: [email protected]