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SOUTHWIRE PRIVACY POLICY

Effective as of: April 15, 2021.

I.    INTRODUCTION 

Southwire Company, LLC and our affiliates (collectively, “Southwire” or “we”)
recognizes that individuals need to understand how their privacy is protected,
so we have established the following privacy policy (this “Privacy Policy”) for
our customers and users. This Privacy Policy describes how Southwire will
collect, access, use and disclose your Personal Information that Southwire
collects in relation to your use of Southwire’s websites, including but not
limited to MySouthwire.com, Southwiretools.com, and GarvinIndustries.com
(collectively, the “Websites”), and that Southwire collects when you place
orders for Southwire products using other methods (e.g., when you place an order
offline, such as with a Southwire representative over the phone, or through a
third-party e-commerce platform).

For purposes of this Privacy Policy, “Personal Information” is information
relating to an identified or identifiable individual. For purposes of this
Privacy Policy, Personal Information does not include de-identified or
aggregated information and, to the extent permitted by law, does not include
publicly available information from government records. 

II.    INFORMATION COLLECTED BY SOUTHWIRE

In order to provide you with the benefits of using our Websites, Southwire
collects certain information from you and your devices. By using the Websites,
purchasing Southwire’s products or otherwise providing Personal Information to
Southwire, you consent to Southwire’s collection, use and sharing of the data as
described in this Privacy Policy.

1.    Categories of Personal Information Collected

We may collect, and may have collected in the twelve (12) months prior to the
date of this Privacy Policy, the following categories of Personal Information:

 * Business contact and shipping information (e.g., name, company name, job
   title, business email address, business phone number, etc.)
 * Personal contact and shipping information (e.g., name, home email address,
   home phone number, etc.)
 * Financial information (e.g., bank account information)
 * Government ID numbers (e.g., FEIN for Southwire’s vendors)
 * Transactional history (e.g., order information and history)
 * Background information, to the extent permitted by law
 * Account login information (e.g., username and password used to create account
   on MySouthwire.com)
 * Website Activity Data (as described further below)
 * Cookie data (as described further below)

2.    Categories of Sources from which Personal Information Is Collected

We may receive, and may have received in the twelve (12) months prior to the
date of this Privacy Policy, Personal Information from the following sources, in
compliance with applicable laws:

 * Directly from you or your device (e.g., when you register for an account on
   the Websites, complete forms on the Websites, make an online or offline
   purchase, communicate with us, or subscribe to our mailing lists)
 * From a Southwire affiliate
 * From a Southwire customer
 * From a Southwire service provider or vendor (e.g., service provider
   collecting information on Southwire’s behalf, or vendor providing information
   that it owns)
 * From third party providers from which you purchase our products (e.g.,
   e-commerce stores, such as Amazon or Home Depot)
 * From consumer reporting agencies

3.    Information Collected from Your Browser or Device

When you visit the Websites, we may automatically gather and store certain
information about your visit from your browser or device, such as your IP
address, geographical information, browser type and version, operating system,
referral sources, and other information relating to your usage of the Websites
(“Website Activity Data”). We may collect this information through the use of
browser information, log files, and other methods.

4.    Information Collected Using Cookies

Cookies are small data files stored on your device by a website. When you visit
the Websites, we may use both session cookies (which expire once you close your
web browser) and persistent cookies (which stay on your device until you delete
them) to make your experience on our Websites more personal and interactive. We
and our analytics providers use both first-party cookies (such as the Google
Analytics cookie) as well as third-party cookies (such as the Google Advertising
cookie). Cookies allow us to collect information such as the pages you viewed on
our Websites, the number of times you accessed our Websites, the amount of time
you spent on our Websites, and other web traffic data. We also use cookies to
conduct analytics on our Websites and for marketing purposes, as described
further below. If you do not wish to have your information collected by using
cookies, you can disable cookies (or specific cookies) by adjusting your browser
settings. Note that if you remove or reject our cookies, it may affect how our
Websites work for you. For more information on the Websites’ use of cookies,
please visit Southwire’s Cookie Notice. For more information on our use of
analytics providers, please see Section V.2 below.

III.    USE AND SHARING OF PERSONAL INFORMATION 

1.    Business or Commercial Purposes for Collection or Use of Personal
Information

Southwire may use, and may have used in the twelve (12) months prior to the date
of this Privacy Policy,  your Personal Information in a variety of ways,
including:

 * To Provide You with Services: We may use your Personal Information to
   maintain your account, process and fulfill your orders and requests, provide
   you with the Websites, verify your identity to use the Websites, provide you
   with customer service, and for troubleshooting, support services, and
   maintenance. 
 * To Communicate with You and Send You Materials:  We may use your Personal
   Information to communicate with you, including regarding your account or your
   orders. We may also use your information to fulfill your requests for
   information or services, including requests to receive our newsletter and
   other materials, and to send you marketing or promotional communications in
   compliance with applicable anti-spam laws. Should you no longer wish to
   receive these marketing or promotional communications, you may opt out as
   described in the “Opting-Out” section below. We may also contact you to ask
   for your feedback.
 * To Manage Our Business and Improve Our Products and Services: We may use your
   Personal Information to manage our business, including performing accounting,
   auditing and other internal and administrative purposes. We may also use your
   information to evaluate and improve our products and services (including our
   Websites), conduct research and perform analysis, learn more about our users
   and customers and identify new customers, and enhance the customer experience
   (including to better optimize and target our marketing and services). We may
   use your information to personalize your experience on the Websites and to
   improve the security, design, and functionality of our Websites.
 * For Other Uses Specifically Identified in Agreements:  We may also use your
   Personal Information for the uses identified in any agreements you may have
   with us, including but not limited to the Southwire Terms of Use, as
   applicable. 
 * Other Uses:  We may also use your Personal Information as described in the
   “Additional Uses and Sharing of Personal Information” section below.

2.    Sharing of Personal Information

Southwire may share, and may have shared in the twelve (12) months prior to the
date of this Privacy Policy, the categories of Personal Information described in
Section II.1 above with the following categories of third parties:

 * With Our Service Providers and Vendors: Southwire may share certain Personal
   Information with third parties acting on our behalf, such as payment
   processors (as described further below), call center operators, consultants,
   professional advisers, data analytics providers, and other service providers
   and vendors.
 * With Our Affiliates:  Southwire may share your Personal Information with our
   affiliates or another member within our group of companies (e.g., with our
   subsidiaries) for the purposes described in this Privacy Policy.
 * With Other Third Parties: We may also share your Personal Information with
   third parties in certain other circumstances that we identify to you (e.g.,
   as needed to provide a service), including the third parties described in the
   “Additional Uses and Sharing of Personal Information” section below.

3.    Additional Uses and Sharing of Personal Information

In addition to the uses and sharing described above, Southwire may also use or
share your Personal Information in the following ways or as otherwise authorized
by law:

 * To comply with laws, regulations, court orders and subpoenas or similar
   requests for information by government or regulatory authorities, or as
   otherwise required by law
 * If we determine a policy violation has occurred, including to enforce the
   Southwire Terms of Use and any other agreements you may have with us
 * To identify, contact or bring legal action regarding injury or interference
   with our rights and property, including to enforce our rights against
   unauthorized access or attempted unauthorized access to our information
   technology assets or against other inappropriate use of our Websites
 * In connection with pending litigation
 * To detect security incidents, investigate and protect against malicious,
   deceptive, fraudulent, or illegal activity, and prosecute those responsible
   for that activity
 * For safety purposes, including to respond to an emergency, and to protect the
   rights, property, safety and security of you and others
 * To debug to identify and repair errors that impair existing intended
   functionality in the Websites
 * In connection with a merger, divestiture, acquisition, 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
 * To report to credit bureaus if applicable

4.    Payment Processors 

All financial transactions conducted in connection with orders placed on our
Websites are securely and directly collected and processed by our third party
payment processor. We do not store any credit card or bank information from such
transactions on our servers. 

5.    No Sale of Personal Information

Southwire has not sold your Personal Information to third parties, including
during the twelve (12) months prior to the date of this Privacy Policy. In
addition, Southwire will not sell your Personal Information to third parties
(including for their own direct marketing purposes) without further notice to
you. If you are entitled to any disclosure rights in your jurisdiction regarding
our sale of your Personal Information to third parties or our disclosure of your
Personal Information to third parties for their own direct marketing purposes,
this disclosure satisfies those requirements. If we are required to obtain your
consent under applicable laws in your jurisdiction regarding our sale of your
Personal Information to third parties, we will comply with such requirements. If
we change our practices in the future for any new information that we collect
from you, we will update this Privacy Policy accordingly. If you still wish to
learn more about our compliance with this requirement, please contact us using
the information provided in the “Contact Us” section below. 

IV.    OPTING-OUT

You may receive email communications from Southwire, including communications
regarding the Websites, marketing or promotions, and/or other topics.  To
contact you, Southwire may use the information you provide to us, including
email, address, fax or phone.  You may also opt-out of promotional email
communications by clicking on a link provided in the promotional email message.

After opting-out, you will no longer receive marketing or promotional
communications but will continue to receive other non-marketing-related
messages, such as emails relating to your orders, your account or your use of
the Websites. 

V.    TRACKING; THIRD PARTY ANALYTICS PROVIDERS

1.    Do Not Track Disclosure

Certain web browsers may provide a do-not-track (“DNT”) option. You may be able
to ask your browser to inform websites that you do not wish your activities to
be tracked, either with cookies or other persistent identifiers, commonly called
“DNT signals.” The Websites currently do not respond to DNT signals.  

2.    Third Party Analytics Providers

We work with third party analytics service providers, including but not limited
to Google Analytics and Facebook Pixel, to help us better understand how you use
the Websites. We use certain third party applications on some of the Websites to
provide services such as analytics or marketing for us. Such third parties may
be able to collect limited information about you, including through the use of
cookies (including tracking cookies), as described above.

Google Analytics; Google Analytics Advertising Features

We use Google Analytics to learn more about the types of users that visit the
Websites and to help improve the Websites. For example, Google Analytics
provides us with certain data regarding the demographics of the users that visit
the Websites. To provide this service, Google Analytics may collect certain
information about you from your computer, including but not limited to:
information regarding your visit (such as the pages you visit and the length of
your visit), information about your device (such as your IP address), how you
got to the Websites, and other information about you. You can learn more about
Google Analytics and how it collects and processes data (including how to
control the information sent to Google) by visiting:
www.google.com/policies/privacy/partners/. You can opt-out of Google Analytics
by using the Google Analytics opt-out browser add-on, available at
https://tools.google.com/dlpage/gaoptout/. You can opt-out of your data being
used by Google Analytics Advertising Features via Google’s Ads Settings page,
available at http://www.google.com/settings/ads/onweb/ or any other available
means (e.g., the NAI’s consumer opt-out, available at
http://www.networkadvertising.org/choices/). Because these opt-out pages are
specific to the individual browser, and because these pages are not operated by
Southwire, we are unable to perform the opt-outs on your behalf.

Facebook Pixel

We use Facebook Pixel on certain of the Websites, including
GarvinIndustries.com, which allows us to display our posted Facebook ads only to
a target group of Facebook users (e.g., users who have shown an interest in our
products or have other similar factors). By using a “visitor action pixel,”
Facebook allows user behavior to be tracked after the user has clicked on a
Facebook ad. In this way, Facebook Pixel enables us to understand the
effectiveness of our Facebook ads for statistical and market research purposes.
Please refer to Facebook’s data policy at
https://www.facebook.com/about/privacy/update for more information. You can
disable this function by going to https://www.facebook.com/settings?tab=ads
while logged into your Facebook account.

Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize
their experience on the Websites. Hotjar is a technology service that helps us
better understand our users’ experience (e.g., how much time they spend on which
pages, etc.). Hotjar uses cookies and other technologies to collect data on our
users’ behavior and their devices (e.g., device's IP address, device screen
size, device type (unique device identifiers), browser information, country
location). Hotjar stores this information in a pseudonymized user profile. For
further details, please see Hotjar’s privacy policy at
https://www.hotjar.com/legal/policies/privacy.

You can opt-out to the creation of a user profile, Hotjar’s storing of data
about your usage of the Websites and Hotjar’s use of tracking cookies on other
websites by going to https://www.hotjar.com/privacy/do-not-track/ .

VI.    CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act (“CCPA”) provides California consumers with
certain rights with regard to their Personal Information. This Section explains
those rights. For purposes of this Privacy Policy, a “California consumer” is a
natural person who resides in California, and does not include persons to the
extent they are (i) acting as an employee, owner, director, officer or
contractor of a company, partnership, sole proprietorship, nonprofit or
government agency that is doing business with Southwire (for example, our
business contacts, vendors and service providers) or (ii) acting as a job
applicant to, an employee of, owner of, director of, officer of, medical staff
member of, or contractor of Southwire. If you are a California consumer and
would like to exercise your CCPA rights, please see Section VI.5 below for more
information on how to submit a request. 

1.    Right to Know About and Access Your Personal Information

If you are a California consumer, you may have the right to request that
Southwire provide you with information regarding what Personal Information about
you we have collected, used, disclosed, or sold in the preceding twelve (12)
months. Once we receive your request and verify your identity, we will disclose
to you one or more of the following as requested:

 * The categories of Personal Information we have collected about you in the
   preceding twelve (12) months.
 * The categories of sources from which we collected your Personal Information
   in the preceding twelve (12) months.
 * The business or commercial purposes for collecting your Personal Information
   in the preceding twelve (12) months.
 * The categories of third parties with whom we shared your Personal Information
   in the preceding twelve (12) months.
 * The specific pieces of Personal Information we collected about you in the
   preceding twelve (12) months.
 * You may only make a consumer request to know about or access  your Personal
   Information twice within a twelve (12)-month period.

2.    Right to Delete Your Personal Information

If you are a California consumer, you may have the right to request that
Southwire delete certain of your Personal Information that we have collected
from you. However, this right to deletion does not apply to any of your Personal
Information that is subject to an exception under the CCPA (as described below).
 Once we receive your request and verify your identity, we will delete your
Personal Information in our records that is not subject to any of the CCPA
exceptions. 

CCPA Exceptions

We may deny your deletion request where your Personal Information is required
for any of the following reasons, which we will identify in our response to you
if we deny your request:

 * 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,
   or otherwise perform our contract with you.
 * Detect security incidents, protect against malicious, deceptive, fraudulent,
   or illegal activity, or prosecute those responsible for such activities.
 * Enable solely internal uses that are reasonably aligned with your
   expectations based on your relationship with us.
 * Comply with a legal obligation.
 * Make other internal and lawful uses of that information that are compatible
   with the context in which you provided it.

3.    Right to Opt-Out of the Sale of Your Personal Information; Right to
Receive Information regarding Sale of Personal Information

If you are a California consumer, you may have the right to opt-out of the sale
of your Personal Information. However, as indicated in Section III.5 above, we
have not sold Personal Information about you to third parties in the twelve (12)
months prior to the date of this Privacy Policy, and we will not sell Personal
Information about you without further notice. If we change our practices in the
future for any new information that we collect from you, we will update this
Privacy Policy accordingly.

If you are a California resident, you may have the right to request and receive
certain information about our disclosure of your Personal Information to third
parties for their own direct marketing purposes, and your choices with respect
to such disclosures. As indicated in Section III.5 above, because it is our
policy not to share your Personal Information with third parties for their own
direct marketing purposes unless you are first given the opportunity to opt-out
from such sharing, we are exempt from having to meet this requirement. If you
still wish to learn more about our compliance with this requirement, please
contact us using the information provided in the “Contact Us” section below.

4.    Right to Non-Discrimination

If you are a California consumer, you have a right to not receive discriminatory
treatment for exercising your privacy rights. Southwire will not discriminate
against any California consumer who exercises any of the rights described above.
Specifically, except as permitted by the CCPA, we will not deny you goods or
services; charge you different prices or rates, including through granting
discounts or other benefits, or imposing penalties; provide you with a different
level of service or quality of goods or services; or suggest that you may
receive a different price or rate for goods or services or a different level or
quality of goods or services.

5.    How to Submit a Request 

If you are a California consumer and would like to exercise any of the CCPA
rights identified above, you may submit a request by either sending an email to
privacy@southwire.com or by calling us at 1-800-339-7348 and providing the
information requested in Section VI.7 below. 

6.    Submitting a Request Through Your Authorized Agent

If you are a California consumer, you may have the option to designate an
authorized agent to submit a request on your behalf, so long as the authorized
agent has your written permission to do so and you have taken steps to verify
your identity directly with us.  If you would like to designate an agent, your
agent must register as such with the California Secretary of State and submit a
copy of this registration along with your consumer request to us. We may need to
contact you directly to verify the request.

7.    How We Verify Your Request

We cannot fulfill your request to provide you with or delete your 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.  

Once you have provided the required information to Southwire, we will confirm
your identity by conducting an electronic search of our internal systems to
ensure the information provided by you in your request matches what we have in
our systems.

To verify your identity, we will ask that you provide the following information
when you submit your request:

 * Your name
 * Your home address and, if different, shipping address
 * Your state of primary residence
 * Your home phone number
 * Your email address
 * Means of purchase (e.g., directly from Garvin, through a third party website,
   such as Amazon, etc.)
 * Date of most recent transaction and description of items purchased

Depending on your type of request or the information requested by you, we may
require additional information in order to verify your identity and fulfill your
request. If we cannot successfully verify your identity, we will inform you of
that fact.

We will respond to your request within forty-five (45) days. However, in certain
circumstances, we may require additional time to process your request, as
permitted by the CCPA or other applicable law. We will advise you within
forty-five (45) days after receiving your request if such an extension is
necessary and why it is needed. Any disclosures we provide will only cover the
twelve (12)-month period preceding our receipt of your request.  If we cannot
fulfill your request, our response to you will also explain the reason why we
cannot fulfill your request.  

We do not charge a fee to process or respond to your 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.

VII.    CANADIAN RESIDENTS: YOUR PRIVACY RIGHTS

Canadian data protection laws provide that Canadian consumers receive certain
notices and that they have certain rights with regard to their Personal
Information. This Section provides those notices and explains those rights. 

Consent. By purchasing our goods and services, submitting information to us in
connection with using our goods or services and/or by visiting, interacting with
and/or using our Websites, you are providing your consent to the collection, use
and disclosure of Personal Information as set out in this Privacy Policy. You
may withdraw consent at any time, subject to legal or contractual restrictions
and reasonable notice. If you withdraw your consent, we may not be able to
provide you with the requested goods or services, and it may impact the
functionality of our Websites. 

Cross-border transfer. In some cases, Personal Information that we manage may be
transferred, processed and stored outside Canada, and therefore may be available
to government authorities under lawful orders and laws applicable in such
foreign jurisdictions.  

Retention. Personal Information will be retained only as long as necessary for
the fulfilment of the purposes for which it was collected and for which consent
was received, unless otherwise required by law. Personal Information that is no
longer required to fulfil the identified purposes will be destroyed, erased or
made anonymous.

Access rights. You have the right to access and rectify the Personal Information
we hold about you. Upon request, we will provide you with access to your
Personal Information within a reasonable timeframe, in compliance with
applicable laws. You can request access or rectification by contacting us as
described in the “Contact Us” section.

VIII.    SAFEGUARDING YOUR INFORMATION

Southwire is committed to maintaining the security of the data you provide us.
However, please note that there is always some risk in transmitting information
over the Internet. Because the Websites are provided through the Internet, when
you use the Websites, your communications may be intercepted by others. For this
reason, Southwire cannot guarantee the security and privacy of transmissions via
the Internet, and we will not be liable for any lack of security relating to the
use of the Websites by you. You agree that you will not hold Southwire liable
for any damages resulting from any loss of privacy or security occurring in
connection with any communications over such networks. 

IX.    EXCLUSIONS 

The Websites may contain links to websites owned by other companies. Because
Southwire has no control over the privacy practices or content of these linked
sites, we recommend that you carefully review the privacy policy of each website
you visit. Southwire is not responsible for the content or privacy practices of
websites owned by other companies. 

This Privacy Policy addresses Southwire’s procedures for handling the Personal
Information of customers who are at least 16 years old. We do not seek to, nor
do we knowingly collect, information from children. If a child has provided us
with Personal Information, a parent or guardian of that child may contact us to
have the information deleted from our records. To do so, contact Southwire
through the information provided below in the “Contact Us” section. 

X.    CONTACT US 

For questions or comments regarding this Privacy Policy, please contact us at: 

By Phone:

1-800-339-7348

By Postal Mail:

Southwire Company, LLC
Attn: Legal Department, General Counsel
One Southwire Drive
Carrollton, GA 30119

USA 

By E-mail:

privacy@southwire.com

XI.    UPDATES TO PRIVACY POLICY

From time to time, we may update this Privacy Policy. If we do, we will note
near the top of this page the date that any changes are made and/or when they
become effective. If the changes being made are material, we may alert you to
the changes in a more prominent way and obtain your consent if required by law.
Your inaction or continued use of the Websites after any such notices, will tell
us that you agree to these changes.

 
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