Privacy Policy

East Penn Manufacturing (hereinafter referred to as “East Penn,” “us,” “we,” “our,” or “Company”) has created this Privacy Policy to apply to all users of this website (https://www.eastpennmanufacturing.com) including our mobile site, contained, or offered therein (collectively, our “Services”). This Privacy Policy describes, among other things, the types of information we collect from users when you use our Services, how we use it, and how you can access your information.

This Privacy Policy is integrated into our Terms & Conditions of Use.

By using the Services and providing us with your personal Information (defined below), you agree to the
practices described in this Privacy Policy and Terms & Conditions referenced below and to the updates
to these policies posted here from time to time.

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or the European Union (EU),
European Economic Area (“EEA”), and United Kingdom (“UK”), you may be entitled to certain individual
rights under the California Consumer Privacy Act of 2018 [as amended by the California Privacy Rights
Act of 2020 (“CPRA”)] (collectively, “CCPA”), Virginia Consumer Data Protection Act (“VCDPA”), Colorado
Privacy Act (“CPA”), Connecticut Act Concerning Personal Data Privacy and Online Monitoring
(“CTDPA”), Utah Consumer Privacy Act (“UCPA”), or the General Data Protection Regulation (“GDPR”)
and the UK Data Protection Act 2018 respectively. Please see the Notice to Certain Residents of Data
Subject Rights Section of our Privacy Policy for your rights and how to exercise them for users located in
California, Virginia, Colorado, Connecticut, Utah, and the EU, EEA, and UK only.

I. INFORMATION WE COLLECT ABOUT YOU

 

We may collect the following categories of information about you which are described in more detail
below: (A) information you provide to us, (B) sensitive information, (C) information we may
automatically collect, and (E) information we may receive from third parties. All of the information
listed in (A)-(C), and (E) above, are detailed below, and hereinafter referred to as “Information.”

A. Information You Provide to Us

In using our Services, you may provide us with Information, including, without limitation:

  • Individual identifiers such as name, contact information such as mailing address, phone
    number, and email address;
  • Authentication data such as account personal information and log in credentials,
    including unique identifiers such as username, account number, and password;
  • Payment and transactional information for products or merchandise purchased. Note
    that we use third party payment processors to facilitate your payments and do not store
    your payment information;
  • Communications with us, preferences, and other Information you provide to us such as
    any messages (including via online chat feature), opinions and feedback that you
    provide to us, your user preferences (such as in receiving updates or marketing
    information), and other Information that you share with us when you contact us directly
    (such as for customer support services); and
  • Additional Information as otherwise described to you at the point of collection or
    pursuant to your consent.

B. Sensitive Information

We do not currently process sensitive personal Information when you use our Services.

C. Information We May Automatically Collect About You

Our Services may automatically collect the following categories of usage and technical Information
about you. This Information is used by East Penn for the operation of the Services, to maintain quality
of the Services, and to provide general statistics regarding use of the Services. This Information may
include:

  • IP address, which is the number associated with the service through which you access
    the internet, like your ISP (internet service provider);
  • Date and time of your visit or use of our Services;
  • Domain server from which you are using our Services;
  • Type of computer, web browsers, search engine used, operating system, or platform
    you use;
  • Data identifying the web pages you visited prior to and after visiting our website or use
    of our Services;
  • Your movement and activity within the website, which is aggregated with other
    Information; and
  • Mobile device Information, including the type of device you use, operating system
    version, and the device identifier (or “UDID”).

D. Cookies & Technologies Used to Collect Information About You

We and/or certain service providers operating on our behalf may collect Information about your activity,
or activity on devices associated with you over time, on our sites and applications, and across non-
affiliated websites or online applications. We may collect this Information by using certain technologies,
such as cookies, web beacons, pixels, software developer kits, third party libraries, and other similar
technologies. Third party service providers, advertisers, and/or partners may also view, edit, or set their
own cookies or place web beacons.

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your
    computer. You may refuse to accept browser cookies by activating the appropriate
    setting on your browser. However, if you select this setting, you may be unable to
    access certain parts of our Services. Unless you have adjusted your browser setting so
    that it will refuse cookies, our system will issue cookies when you direct your browser to
    our website.
  • Web Beacons. Website pages may contain small electronic files known as web beacons
    (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for
    example, to count users who have visited those pages and for other related statistics
    (for example, recording the popularity of certain content and verifying system and
    server integrity). We also use these technical methods to analyze the traffic patterns,
    such as the frequency with which our users visit various parts of the Services. These
    technical methods may involve the transmission of Information either directly to us or
    to a third party authorized by us to collect Information on our behalf. Our Services use
    retargeting pixels from Google, Facebook, and other ad networks. We also use web
    beacons in HTML emails that we send to determine whether the recipients have opened
    those emails and/or clicked on links in those emails.
  • Analytics. Analytics are tools we may use, such as Google Analytics, to help provide us
    with information about traffic to our website and use of our Services, which Google may
    share with other services and websites who use the collected data to contextualize and
    personalize the ads of its own advertising network. You can view Google’s Privacy
    Practices here: Privacy Policy – Privacy & Terms – Google.
  • Mobile Application Technologies. If you access our website and Services through a
    mobile device, we may automatically collect Information about your device, your phone
    number, and your physical location.

Our use of online tracking technologies may be considered a “sale” or “sharing” under certain laws. To
the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under certain
laws, you can opt-out of these online tracking technologies by broadcasting an opt-out preference
signal, such as the Global Privacy Control (GPC). Please note that some features of our website may not
be available to you as a result of these choices.

E. Information We May Receive from Third Parties

We may collect additional Information about you from third party websites, social media platforms,
and/or sources providing publicly available information (e.g., from the U.S. postal service) to help us
provide services to you, help prevent fraud, and for marketing and advertising purposes.
This Privacy Policy only applies to Information collected by our Services. We are not responsible for the
privacy and security practices of those other websites or Social Media Platforms or the Information they
may collect (which may include IP address). You should contact such third parties directly to determine
their respective privacy policies. Links to any other websites or content do not constitute or imply an
endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

II. HOW WE USE YOUR INFORMATION

 

A. Use and Purpose of Processing Your Information

We use and process your Information for things that may include, but are not limited to, the following:

  • To provide you with the Services and Information you request;
  • To respond to your inquiries and questions and provide customer service;
  • To process your product purchase request;
  • To help you locate retailer, distributor, and wholesaler locations near you;
  • For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted-out of receiving such communications;
  • To fulfill contracts we have with you;
  • To manage, improve, and foster relationships with third party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners;
  • Maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and services;
  • Comply with our Terms & Conditions;
  • Analytics for business purposes and business intelligence;
  • Comply with any applicable laws and regulations and respond to lawful requests; and/or
  • For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent.

We may also use Information that has been de-identified and/or aggregated for purposes not otherwise listed above.

B. Sharing or Disclosing Your Information

We may share and/or disclose your Information as set forth in the Privacy Policy and in the following
circumstances:

  • Third Party Service Providers. We may share your Information with third party service
    providers that perform certain functions or services on our behalf (such as to host the
    Services, manage databases, perform analyses, process credit card payments, provide
    customer service, or send communications for us). These third party service providers
    are authorized to use your Information only as necessary to provide these services to us.
    In some instances, we may aggregate Information we collect so third parties do not
    have access to your identifiable Information to identify you individually.
  • Disclosure of Information for Legal and Administrative Reasons. We may disclose your
    Information without notice: (i) when required by law or to comply with a court order,
    subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an
    internal or external investigation or audit; (iii) to comply with legal, regulatory, or
    administrative requirements of governmental authorities (including, without limitation,
    requests from the governmental agency authorities to view your Information); (iv) to
    protect and defend the rights, property, or safety of us, our subsidiaries and affiliates,
    and any of their officers, directors, employees, attorneys, agents, contractors, and
    partners, and the website Service users; (v) to enforce or apply our Terms & Conditions;
    and (vi) to verify the identity of the user of our Services.
  • Business Transfers. Your Information may be transferred, sold, or otherwise conveyed
    (“Conveyed”) to a third party where we: (i) merge with or are acquired by another
    business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt;
    or (iv) are liquidated or otherwise reorganize.
  • Information Shared with our Subsidiaries and Affiliates. We may share your
    Information with our subsidiaries and affiliates.
  • De-Identified or Aggregated Data. We may share your Information on an aggregated
    basis for any purpose in which your specific personal Information is blinded, masked, or
    otherwise not identifiable.
  • With Your Consent. We may share Information consistent with this Privacy Policy with
    your consent.

C. Categories of Information Sold

We do not sell or share any categories of personal Information. For purposes of this Privacy Policy,
“sell”, “sold,” or “sale” means the disclosure of personal Information for monetary or other valuable
consideration but does not include, for example, the transfer of personal Information as an asset that is
part of a merger, bankruptcy, or other disposition of all or any portion of our business.

III. LINKS TO OTHER WEBSITES

v

Our Services may contain links to other websites or services that are not owned or controlled by us,
including links to Social Media Platforms such as Facebook, Instagram, or YouTube, or may redirect you
off our website away from our Services.

This Privacy Policy only applies to Information collected by our Services. We are not responsible for the
privacy and security practices of those other websites or Social Media Platforms or the Information they
may collect (which may include IP address). You should contact such third parties directly to determine
their respective privacy policies. Links to any other websites or content do not constitute or imply an
endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

IV. INFORMATION SECURITY

 

We use commercially reasonable and appropriate administrative, physical, and technical security
measures to provide our Services and safeguard your Information. However, no data transmitted over
the Internet or stored or maintained by us or our third-party service providers can be 100% secure.
Therefore, we do not promise or guarantee, and you should not expect, that your Information or private
communications will always remain private or secure. We do not guarantee that your Information will
not be misused by third parties. We are not responsible for the circumvention of any privacy settings or
security features. You agree that we will not have any liability for misuse, access, acquisition, deletion,
or disclosure of your Information.

If you believe that your Information has been accessed or acquired by an unauthorized person, you
should promptly Contact Us so that necessary measures can quickly be taken.

V. DATA RETENTION

 

We will retain your Information for as long as needed to provide you Services, and as necessary to
comply with our legal obligations, resolve disputes, and enforce our policies. We will retain and use
your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our
agreements. In accordance with our routine record keeping, we may delete certain records that contain
Information you have submitted to us. We are under no obligation to store such Information
indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.

VI. YOUR CHOICES

 

  • A. Marketing Communications. If you do not want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt-out of marketing email communications or see How to Contact Us below for more information.
  • B. Opting Out of Direct Marketing by Third Parties. To exercise choices regarding the marketing information you receive, you may also review the following links:

  • You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.
  • You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-
    out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at
    http://optout.aboutads.info.
  • You can opt-out of having your activity on our Services made available to Google
    Analytics by installing the Google Analytics opt-out add-on for your web browser by
    visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

VII. NOTICE TO CERTAIN RESIDENTS OF DATA SUBJECT RIGHTS

 

A. NOTICE TO CALIFORNIA RESIDENTS
 

To the extent any California data privacy law applies to the collection of your Information, this
supplemental section of our Privacy Policy outlines the rights that California residents may have, and
how they can exercise those rights. This notice applies solely to California residents. We provide the
supplemental section below to comply with the California Consumer Privacy Act [as amended by the
California Privacy Rights Act (referred to collectively hereinafter as CCPA)] and any terms defined in the
CCPA have the same meaning when used below.

1. Your Rights under CCPA

  • Right to Know and Access Specific Information. You have the right to request that
    we disclose certain information to you about our collection and use of your
    Information over the past twelve (12) months. Once we receive and confirm a
    verifiable consumer request from you, we will disclose to you, to the extent
    permitted by law:

  • The categories of Information we collected about you, and whether we sell or
    share your Information to third parties;
  • The specific pieces of Information we hold about you;
  • The categories of personal Information sold within the last twelve (12) months;
  • The categories of sources from which Information about you is collected;
  • Our business or commercial purpose for collecting, selling, or sharing your Information; and
  • The categories of third parties with whom your Information is sold, shared, or
    disclosed for a business purpose.

    • You have the right to request that the Information described above be provided to
    you in a portable and readily useable format, to the extent technically feasible
    (“data portability”).

  • Deletion Request Rights. You have the right to request that we delete the
    Information that we collected from you, subject to certain exceptions. To the
    extent that we can delete your Information, once we receive and confirm your
    verifiable consumer request, we will delete (and direct our service providers to
    delete) your Information, unless an exception applies.
  • Right to Correct Inaccurate Information. To the extent that we may maintain
    inaccurate personal Information, you have the right to request that we correct such
    inaccurate personal Information taking into account the nature of the personal
    Information and the purposes of the processing of the personal Information. Once
    we receive and verify your verifiable consumer request, we will use commercially
    reasonable efforts to correct your personal Information.
  • Sale and Sharing of Personal Information and the Right to Opt-Out. You have the
    right to opt out of the processing of your Information for the following purposes:
  • Sale of your Information; and
  • Sharing of your Information for cross-context behavioral advertising.

    • The use of online tracking technologies may be considered a “sale” or “sharing”
    under California law. To the extent that these online tracking technologies are
    deemed to be a “sale” or “sharing” under California law, you may opt-out of these
    online tracking technologies by broadcasting an opt-out preference signal, such as
    the Global Privacy Control (GPC).

  • Right to Limit Use and Disclosure of Sensitive Personal Information. You have the
    right to request that we limit the ways we use and disclose your sensitive personal
    Information (as defined by CCPA) to uses which are necessary for us to perform the
    Services, or deliver the goods reasonably expected by you, or and as authorized by
    law.
  • Right to Non-Discrimination. You have a right to not be discriminated against in the
    Services or quality of Services you receive from us for exercising your rights. We
    may not, and will not, treat you differently because of your data subject request
    activity. As a result of your data subject request activity, we may not and will not
    deny goods or Services to you, charge different rates for goods or Services, provide
    a different level quality of goods or Services, or suggest that we would treat you
    differently because of your data subject request activity.
  • Right to Disclosure of Direct Marketers. You have a right to the categories and
    names/addresses of third parties that have received personal Information for their
    direct marketing purposes upon simple request, and free of charge.

You may make an authenticated consumer request exercising your Right to Know and Access Specific
Information including right to know what personal Information is being sold or shared under the CCPA
twice within a twelve (12) month period. To exercise the rights described above, see the Exercising Your
Rights section below.

2. Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf provided that
the authorized agent is a natural person or a business entity that you have authorized to act on your
behalf. If you use an authorized agent, we will require: (1) proof of written permission for the
authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of
power of attorney pursuant to California Probate Code sections 4000 to 4665. We may deny a request
from an authorized agent that does not submit proper verification proof.

3. Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

B. NOTICE TO VIRGINIA RESIDENTS

 

To the extent any Virginia data privacy law applies to the collection of your Information, this
supplemental section of our Privacy Policy outlines the individual rights guaranteed to Virginia residents
and how to exercise those rights and applies solely to Virginia residents. We provide the supplemental
section below to comply with the Virginia Consumer Data Protection Act (“VCDPA”) and any terms
defined in the VCDPA have the same meaning when used below.

1. Your Rights under VCDPA

Subject to certain exceptions you may be entitled to the following rights:

  • Right to Access & Data Portability. You have the right to request that we disclose
    certain information to you about our collection and use of your Information at any
    time. Once we receive and confirm an authenticated consumer request from you,
    we will, subject to certain exceptions:
  • Disclose whether or not we are processing your Information; and
  • Provide you with access to your Information.

    • Where the processing is carried out by automated means, and subject to certain
    exceptions, you have the right to request and obtain a copy of your Information that
    you previously provided to us in a portable and, to the extent technically feasible,
    readily usable format that allows you to transmit the Information to another data
    controller without hindrance.

  • Right to Correct Inaccurate Information. To the extent that we may maintain
    inaccurate Information, you have the right to request that we correct such
    inaccurate Information taking into account the nature of the personal Information
    and the purposes of the processing of the personal Information. Once we receive
    and verify your authenticated consumer request, we will use commercially
    reasonable efforts to correct your Information.
  • Right to Delete. You have the right to request that we delete certain of your
    Information provided by or obtained about you. To the extent that we can delete
    your Information, once we receive and confirm your authenticated consumer
    request, we will delete (and direct our service providers to delete) your Information,
    subject to certain exceptions.
  • Sale of Personal Information, Targeted Advertising, Profiling, and the Right to Opt-
    Out.     You have the right to opt out of the processing of your Information for the
    following purposes:
  • Targeted advertising;
  • Sale of your Information; and
  • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • Right to Appeal. You have the right to appeal our denial of any request you make
    under this section. To exercise your right to appeal, please submit an appeals
    request via the information in the How To Contact Us section below. Within sixty
    (60) days of receipt of your appeal, we will inform you in writing of any action taken
    or not taken in response to your appeal, including a written explanation of the
    reasons for the decisions. If we deny your appeal, you may contact the Virginia
    Office of the Attorney General by:
  • Contacting Online: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint
  • Calling:
  • If calling from Virginia, call the Consumer Protection Hotline at 1-800-552-9963.
  • If calling from the Richmond area or from outside Virginia, call the Consumer Protection Hotline at 1-804-786-2042.
  • Right to Non-Discrimination. You have a right to not be discriminated against in the
    Services or quality of Services you receive from us for exercising your rights. We will
    not discriminate against you for exercising any of your rights in this section including
    denying goods or Services, charging different prices or rates for goods or Services, or
    providing a different level of quality of goods and Services. However, we may offer
    a different price, rate, level, quality, or selection of goods or Services, including
    offering goods or Services for no fee, if you have exercised your right to opt out or
    the offer is related to your voluntary participation in a bona fide loyalty, rewards,
    premium features, discounts, or club card program.

You may make an authenticated consumer request under the VCDPA twice within a twelve (12) month
period. To exercise the rights described above, see the Exercising Your Rights section below.

2. Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your
request.

C. NOTICE TO COLORADO RESIDENTS

 

To the extent any Colorado data privacy law applies to the collection of your Information, this
supplemental section of our Privacy Policy outlines the individual rights guaranteed to Colorado
residents and how to exercise those rights and applies solely to Colorado residents. We provide the
supplemental section below to comply with the Colorado Privacy Act (“CPA”) and any terms defined in
the CPA have the same meaning when used below.

1. Your Rights under CPA

Subject to certain exceptions you may be entitled to the following rights:

  • Right to Access & Data Portability. You have the right to request that we disclose
    certain information to you about our collection and use of your Information at any
    time. Once we receive and confirm an authenticated consumer request from you,
    we will, subject to certain exceptions:
  • Disclose whether or not we are processing your Information; and
  • Provide you with access to your Information where we process it.

    • Where exercising your right to access, you have the right to request and obtain a
    copy of your Information that you previously provided to us in a portable and, to the
    extent technically feasible, readily usable format that allows you to transmit the
    Information to another data controller without hindrance (“data portability”).

  • Right to Correct Inaccurate Information. To the extent that we may maintain
    inaccurate personal Information, you have the right to request that we correct such
    inaccurate personal Information taking into account the nature of the personal
    Information and the purposes of the processing of the personal Information. Once
    we receive and verify your authenticated consumer request, we will use
    commercially reasonable efforts to correct your personal Information.
  • Right to Delete. You have the right to request that we delete certain of your
    Information provided by or obtained about you. To the extent that we can delete
    your Information, once we receive and confirm your authenticated consumer
    request, we will delete your Information, subject to certain exceptions.
  • Sale of Personal Information, Targeted Advertising, Profiling, and the Right to Opt-
    Out.     You have the right to opt out of the processing of your Information for the
    following purposes:
  • Targeted advertising;
  • Sale of your Information; and
  • Profiling in furtherance of decisions that produce legal or similarly significanteffects concerning you.
  • Right to Appeal. You have the right to appeal our denial of any request you make
    under this section. To exercise your right to appeal, please submit an appeals
    request via the information in the How To Contact Us section below. Within forty-
    five (45) days of receipt of your appeal, we will inform you in writing of any action
    taken or not taken in response to your appeal, including a written explanation of the
    reasons for the decisions. If you have concerns regarding the results of your appeal,
    you may contact the Colorado Office of the Attorney General by:
  • Contacting Online: https://complaints.coag.gov/s/contact-us
  • Calling: (720) 508-6000

You may make an authenticated consumer request free of charge under the CPA once within a twelve
(12) month period. We reserve the right to charge a reasonable fee for a second or subsequent request
within the same twelve (12) month period. To exercise the rights described above, see the Exercising
Your Rights section below.

2. Sensitive Data

We do not process sensitive data including sensitive data inferences. When we process sensitive data,
we do so with your consent.

3. Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf. An authorized
agent is a natural person or a business entity that you have authorized to act on your behalf. If you use
an authorized agent, we will require: (1) proof of written permission for the authorized agent to make
requests on your behalf, and identity verification from you; or (2) proof of power of attorney. We may
deny a request from an authorized agent that does not submit proper verification proof.

D. NOTICE TO CONNECTICUT RESIDENTS

To the extent any Connecticut data privacy law applies to the collection of your Information, this
supplemental section of our Privacy Policy outlines the individual rights guaranteed to Connecticut
residents and how to exercise those rights and applies solely to Connecticut residents. We provide the
supplemental section below to comply with the Connecticut Act Concerning Personal Data Privacy and
Online Monitoring (“CTDPA”) and any terms defined in the CTDPA have the same meaning when used
below.

1. Your Rights under CTDPA

Subject to certain exceptions you may be entitled to the following rights:

  • Right to Access & Data Portability. You have the right to request that we disclose
    certain information to you about our collection and use of your Information at any
    time. Once we receive and confirm an authenticated consumer request from you,
    we will, subject to certain exceptions:
  • Disclose whether or not we are processing your Information; and
  • Provide you with access to your Information where we process it.

    • Where the processing is carried out by automated means, and subject to certain
    exceptions, you have the right to request and obtain a copy of your Information that
    you previously provided to us in a portable and, to the extent technically feasible,
    readily usable format that allows you to transmit the Information to another data
    controller without hindrance.

  • Right to Correct Inaccurate Information. To the extent that we may maintain
    inaccurate personal Information, you have the right to request that we correct such
    inaccurate personal Information taking into account the nature of the personal
    Information and the purposes of the processing of the personal Information. Once
    we receive and verify your authenticated consumer request, we will use
    commercially reasonable efforts to correct your personal Information.
  • Right to Delete. You have the right to request that we delete certain of your
    Information provided by or obtained about you. To the extent that we can delete
    your Information, once we receive and confirm your authenticated consumer
    request, we will delete (and direct our service providers to delete) your Information,
    subject to certain exceptions.
  • Sale of Personal Information, Targeted Advertising, Profiling, and the Right to Opt-
    Out.     You have the right to opt out of the processing of your Information for the
    following purposes:
  • Targeted advertising;
  • Sale of your Information; and
  • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • Right to Non-Discrimination. You have a right to not be discriminated against in the
    Services or quality of Services you receive from us for exercising your rights. We will
    not discriminate against you for exercising any of your rights in this section including
    denying goods or Services, charging different prices or rates for goods or Services, or
    providing a different level of quality of goods and Services. However, we may offer
    a different price, rate, level, quality, or selection of goods or Services, including
    offering goods or services for no fee, if you have exercised your right to opt out or
    the offer is related to your voluntary participation in a bona fide loyalty, rewards,
    premium features, discounts, or club card program.
  • Right to an Appeal. You have the right to appeal our denial of any request you
    make under this Section. To exercise your right to appeal, please submit appeals
    request to us by either:
  • Emailing us at eastpenn@eastpenn-deka.com
  • Calling us at?610-682-6361

Within sixty (60) days of receipt of your appeal, we will inform you in writing of any
action taken or not taken in response to your appeal, including a written
explanation of the reasons for the decisions. If we deny your appeal, you may
contact the Connecticut Office of the Attorney General by:

You may make an authenticated consumer request under the CTDPA once within a twelve (12) month
period. To exercise the rights described above, see the Exercising Your Rights section below.

2. Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf. An authorized
agent is a natural person or a business entity that you have authorized to act on your behalf. If you use
an authorized agent, we will require: (1) proof of written permission for the authorized agent to make
requests on your behalf, including through technology means, and identity verification from you; or (2)
proof of power of attorney. We may deny a request from an authorized agent that does not submit
proper verification proof.

3. Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your
request.

E. NOTICE TO UTAH RESIDENTS

 

To the extent any Utah data privacy law applies to the collection of your Information, this supplemental
section of our Privacy Policy outlines the individual rights guaranteed to Utah residents and how to
exercise those rights and applies solely to Utah residents. We provide the supplemental section below
to comply with the Utah Consumer Privacy Act (“UCPA”) and any terms defined in the UCPA have the
same meaning when used below.

1. Your Rights under UCPA

Subject to certain exceptions you may be entitled to the following rights:

  • Right to Access & Data Portability. You may have the right to request that we
    disclose certain information to you about our collection and use of your Information
    at any time. Once we receive and confirm an authenticated consumer request from
    you, we will, subject to certain exceptions:
  • Disclose whether or not we are processing your Information; and
  • Provide you with access to your Information where we process it.

    • Where the processing is carried out by automated means, and subject to certain
    exceptions, you have the right to request and obtain a copy of your Information that
    you previously provided to us in a portable and, to the extent technically feasible,
    readily usable format that allows you to transmit the Information to another data
    controller without hindrance (“data portability”).

  • Right to Delete. You have the right to request that we delete certain of your
    Information provided by or obtained about you. To the extent that we can delete
    your Information, once we receive and confirm your authenticated consumer
    request, we will delete (and direct our service providers to delete) your Information,
    subject to certain exceptions.
  • Right to Non-Discrimination. We will not discriminate against you for exercising
    any of your rights in this section including denying goods or Services, charging
    different prices or rates for goods or Services, or providing a different level of
    quality of goods and services.
  • Sale of your Personal Information, Targeted Advertising, and Right to Opt-Out.
    You have the right to opt out of the processing of your Information for the following
    purposes:
  • Targeted advertising; and
  • Sale of your Information.

You may make an authenticated consumer request free of charge under the UCPA once within a twelve
(12) month period. We reserve the right to charge a reasonable fee for a second or subsequent request
within the same twelve (12) month period. To exercise the rights described above, see the Exercising
Your Rights section below.

F. NOTICE TO INDIVIDUALS IN THE EUROPEAN UNION, THE EUROPEAN ECONOMIC AREA, AND THE UK

 

This section applies only to individuals coming to our Services from within the European Union (EU), the
European Economic Area (EEA), and the UK, and only if we collect through the Services any Information
from you that is considered “Personal Data,” as defined in the General Data Protection Regulation
(GDPR) and the UK Data Protection Act 2018.

Personal Data includes any information relating to an identified or identifiable natural person, who
could be identified either directly or indirectly by reference to an identifier such as a name, an
identification number, location data, an online identifier, or to one or more factors specific to the
physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person
(which may include some or all your Information as defined in this Privacy Policy).

1. Identity and Contact Details of Privacy Contact

Unless otherwise stated, we are the Data Controller for the Information we process.

Contact Details:
Email: eastpenn@eastpenn-deka.com
Call us: +1(610) 682-3661

Write us:
East Penn Manufacturing Co.
Attn: Marketing Dept.
102 Deka Rd.
Lyons, PA 19536

2. Your Data Protection Rights

To the extent the GDPR and Data Protection Act 2018 apply, and we hold your Information in our
capacity as a Data Controller as defined under those laws, you may request that we:

  • Restrict the way that we process and share your Information;
  • Transfer your Information to a third party;
  • Provide you with access to your Information;
  • Remove your Information if no longer necessary for the purposes collected;
  • Update your Information so it is correct and not out of date; and/or
  • Object to our processing of your Information.

You may also revoke your consent for processing of your Information. If you wish to object to the use
and processing of your Information or withdraw consent to this Privacy Policy, you can contact us in the
following ways:

Email: eastpenn@eastpenn-deka.com
Call us: +1(610) 682-3661
Write us:
East Penn Manufacturing Co.
Attn: Marketing Dept.
102 Deka Rd.
Lyons, PA 19536

The requests above will be considered and responded to in the time-period stated by applicable law.
Note, certain Information may be exempt from such requests. We may require additional Information
from you to confirm your identity in responding to such requests.

You have the right to lodge a complaint with the supervisory authorities applicable to you and your
situation, although we invite you to contact us with any concern as we would be happy to try and
resolve it directly. Please contact us at:

Email: eastpenn@eastpenn-deka.com
Call us: +1(610) 682-3661
Write us:
East Penn Manufacturing Co.
Attn: Marketing Dept.
102 Deka Rd.
Lyons, PA 19536

3. Lawful Basis for Processing Your Information

The lawful basis for our processing of your Personal Data will depend on the purposes of the processing.
For most Personal Data processing activities covered by this Privacy Policy, the lawful basis is that the
processing is necessary for our legitimate business interests. Where we process Personal Data in
relation to a contract or a potential contract with you, the lawful basis is that the processing is necessary
for the performance of our contract with you or to take steps at your request prior to entering into a
contract. If we are required to share Personal Data with law enforcement agencies or other
governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also
use consent as the legal basis where we deem appropriate or to the extent required by applicable law,
for example, before we collect precise location data from your mobile device.

Depending on what Personal Data we collect from you and how we collect it, we may also rely on
various grounds for processing your Personal Data, including the following reasons:

  • Processing on the basis of legitimate business interests. When we process Personal
    Data on the basis that the processing is necessary for our legitimate business interests,
    such interests include: (i) providing, improving, and promoting our Services; (ii)
    communicating with current and potential customers, other business partners, and their
    individual points of contact; (iii) managing our relationships with our customers and
    other business partners, and their individual points of contact; (iv) other business
    development purposes; (v) sharing information within the Company, as well as with
    service providers and other third parties; and (vi) maintaining the safety and security of
    our products, Services, and employees, including fraud protection.
  • Processing on the basis of performance of a contract. Examples of situations in which
    we process Personal Data as necessary for performance of a contract include e-
    commerce transactions in which you purchase a service from us.
  • Processing on the basis of consent. Examples of processing activities for which we may
    use consent as its legal basis include: (i) collecting and processing precise location
    information from your mobile device; (ii) sending promotional emails when consent is
    required under applicable law; and (iii) processing Personal Data on Company Services
    through cookies and similar technologies when consent is required by applicable law.
  • Processing because we are under a legal obligation to do so. Examples of situations in
    which we must processes Personal Data to comply with our legal obligations include: (i)
    providing your Personal Data to law enforcement agencies and other governmental
    bodies when required by applicable laws; (ii) retaining business records required to be
    retained by applicable laws; and (iii) complying with court orders or other legal process.

If the processing of your Information is based on your consent, the GDPR and Data Protection Act 2018
also allow users the right to access, revoke, or modify your consent at any time. Please see the How to
Contact Us section, below, to review or modify your consents.

4. Consent to Transfer

We are operated in the United States, and we may use service providers based in the United States to
operate our business and our relationship with you. Please be aware that Information, including your
Personal Data, that we collect will be transferred to, stored, and processed in the United States, a
jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you
reside and/or are a citizen. We maintain measures to address the transfer of your Personal
Data between our group companies and between us and our third-party providers in accordance with
applicable data protection laws and regulations.

5. Retention

We will retain your Information for as long as needed for the purposes described in this Privacy Policy.
More specifically, the time we maintain your Information depends on the following factors:

  • Whether we need the Information to provide the Services. We will maintain any data
    needed to provide you with the Services, such as contact information and payment or
    transaction information, for as long as needed for us to provide you with the Services,
    respond to your questions and requests, and/or administer your account (if applicable).
  • Whether we need the Information to comply with our legal obligations. We may have
    legal obligations to maintain your Information where a legal or regulatory body may ask
    for it in the future, for example in response to a data subject request or complaint. This
    information may include contact information and location information.
  • Whether we need the Information for a legitimate business interest. We may store
    Information like contact information, cookies, and location information in order to
    perform analytics, troubleshoot errors, or improve our Services. In any event, we delete
    the Information when it is no longer needed for our legitimate interest.

Regardless of our reason for retaining your information, we delete all Information in accordance with
our routine record keeping policies.

VIII. EXERCISING YOUR DATA SUBJECT RIGHTS

 

To exercise any of the rights described above, please submit a verifiable consumer request to us via the
methods described below. The verifiable consumer request must:

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

To help protect your privacy and maintain security, if you request access to or deletion of your
Information, we will take steps and may require you to provide certain information to verify your
identity before granting you access to your Information or complying with your request. In addition, if
you ask us to provide you with specific pieces of Information, we may require you to sign a declaration
under penalty of perjury that you are the consumer whose Information is the subject of the request.
Only you or your authorized agent may make a verifiable consumer request related to your Information.
If you designate an authorized agent to make a request on your behalf, we may require you to provide
the authorized agent written permission to do so and to verify your own identity directly with us (as
described above). You may also make a verifiable consumer request on behalf of your minor child.

Email: eastpenn@eastpenn-deka.com
Call us: +1(610) 682-3661
Write us:
East Penn Manufacturing Co.
Attn: Marketing Dept.
102 Deka Rd.
Lyons, PA 19536

IX. GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING

 

Our Services are targeted to individuals located in the United States. As such, the Services collect
Information and process and store that Information in databases located in the United States. If you are
visiting the Services from a country outside the United States, you should be aware that you may
transfer personally identifiable Information about yourself to the United States, and that the data
protection laws of the United States may not be as comprehensive as those in your own country. By
visiting the Services and submitting any personally identifiable Information you consent to the transfer
of such personally identifiable Information to the United States.

X. CHILDREN’S INFORMATION

The Services are intended only for users over the age of sixteen (16). If we become aware that a user is
under sixteen (16) (or a higher age threshold where applicable) and has provided us with Information,
we will take steps to comply with any applicable legal requirement to remove such Information. Contact
us if you believe that we have mistakenly or unintentionally collected Information from a child under the
age of sixteen (16).

XI. DIFFICULTY ACCESSING OUR PRIVACY POLICY

Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us to
inquire how they can obtain a copy of our policy in another, more easily readable format.

XII. “DO NOT TRACK” SIGNALS

We do not support “Do Not Track.” Do Not Track is a preference you can set in your web browser to
inform websites that you do not want to be tracked. You can enable or disable “Do Not Track” by
visiting the “Preferences” or “Settings” page of your web browser. Do Not Track is different from Global
Privacy Controls (“GPC”), which may notify websites of consumers’ privacy preferences regarding the
sale or sharing of personal Information, or the use of sensitive personal Information.

XIII. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change, modify, or amend this Privacy Policy at any time to reflect changes in
our products and service offerings, accommodate new technologies, regulatory requirements, or other
purposes. If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be
effective upon posting. It is your obligation to check our current Privacy Policy for any changes.

XIV. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Information we have collected about you, please contact us at the following:

Email: eastpenn@eastpenn-deka.com
Call us: +1(610) 682-3661
Write us:
East Penn Manufacturing Co.
Attn: Marketing Dept.
102 Deka Rd.
Lyons, PA 19536

Effective Date: February 20th, 2023