Privacy Notice

Last Updated: June 30, 2025

Introduction

Ingram Content Group and its related and affiliated companies (“Ingram”, “we”, “us”, and “our”) respect your privacy and are committed to protecting it through our compliance with the practices described herein. This Privacy Notice (the “Notice”) describes the types of information we may collect from you or that you may provide when you visit our websites that link to this Notice (the “Website”) as well as our practices when collecting, disclosing, maintaining, and using that information. It also describes the options you may have regarding collecting, disclosing, and using your personal information.

By using our Website(s) and/or registering for any of our offerings, you accept the privacy practices described in this Notice and consent to our collection, disclosure, and use of your personal information. If you do not agree with this Notice, do not use our Website. We may modify the terms of this Notice at any time and will post any changes on the Website. Your continued use of the Website following the posting of changes is your acknowledgment of acceptance.

On occasion, we may offer special activities, events, programs, or promotions (“Programs”) that have unique or additional terms, notices, or consent requirements to explain how the information you provide will be processed in connection with the Programs. You should review those applicable terms, where applicable, before interacting or participating in the Programs.

Our Role and Contact Information. We act as the “data controller” with respect to the information described in this Notice. Our contact information is provided at the end of this Notice.

HOW DO WE PROCESS PERSONAL DATA?

What Personal Information Do We Collect? We collect the following types of personal data for the purposes listed below. For residents of California, pursuant to the California Consumer Privacy Act, as amended (“CCPA”), we have identified the categories of personal information collected in addition to the purposes described below.

Category

Description

Contact Information

If you contact us (including signing up for communications or participating in promotions or Programs), we will receive your name, title, company/organization name and type, mailing address, country, email address, phone number, fax number, and other information that you share with us. If you visit one of our facilities, we may require you to sign-in.

We process Contact Information to operate our Website and business; to provide, optimize, and improve our products and services; to provide customer support; to verify and update your information; to ensure the privacy and security of our Website and operations; to authenticate your login; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to perform statistical, demographic, and marketing analyses; to administer contests, promotions, sweepstakes, offers, promotions, forms, and surveys; to communicate with you; to respond to your request; to complete transactions you request; to keep records of our communications with you; to determine user interests; to develop new products and services; and for usage analytics purposes.

The legal basis for this processing is our legitimate interest in the proper administration of our Website and business, the proper management of our relationships, and, where applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

CCPA Categories: Identifiers; Categories Described in the Customer Records Statute

Communications

If you contact us, in addition to your Contact Information, we will receive any comments, content, questions, complaints, customer service requests, or other information that you choose to provide. You can decide how much information you want to share with us in those communications.

We process Communications to operate our Website and business; to provide,optimize, and improve our products and services; to provide customer support;to verify and update your information; to ensure the privacy and security of our Website and operations; to authenticate your login; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to perform statistical, demographic, and marketing analyses; to administer contests, promotions, sweepstakes, offers, promotions, forms, and surveys; to communicate with you; to respond to your request; to complete transactions you request; to keep records of our communications with you; to determine user interests; to develop new products and services; and for usage analytics purposes.

The legal basis for this processing is our legitimate interest in the proper administration of our Website and business, the proper management of our relationships, and, where applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Commercial Information

Account Information

When you create an account or register with us, in addition to your Contact Information, we collect your username or account ID and the password that you choose to create. You may be required to create an account to access certain features of the Website.

We process Account Information to operate our Website and business; to provide, optimize, and improve our products and services; to provide customer support; to verify and update your information; to ensure the privacy and security of our Website and operations; to authenticate your login; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to perform statistical, demographic, and marketing analyses; to administer contests, promotions, sweepstakes, offers, promotions, forms, and surveys; to communicate with you; to respond to your request; to complete transactions you request; to keep records of our communications with you; to determine user interests; to develop new products and services; and for usage analytics purposes.

The legal basis for this processing is our legitimate interest in the proper administration of our Website and business, the proper management of our relationships, and, where applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Commercial Information; Sensitive Personal Information

Interactive Features

If you use certain interactive features on our Website, such as submitting comments or product ratings and reviews, you may also provide us with your Contact Information and other information like your nickname, ratings, comments, or pictures. In addition, we may give you the opportunity to tell your friends about certain features or information on our Website, including via social media.

You may also share with us contact information of friends and people in your address book, so we can help you let your friends know about special offers and help with product shipments. Please be mindful of your privacy needs and those of others as you choose who to connect with, what you share with us and others, and what you make public. We are not responsible for the personal information you make public or share with others using our Website.

We use information from Interactive Features to operate our Website and business; to provide, optimize, and improve our products and services; to provide customer support; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to perform statistical, demographic, and marketing analyses; to administer contests, promotions, sweepstakes, offers, promotions, forms, and surveys; to communicate with you; to respond to your request; to keep records of our communications with you; to determine user interests; to develop new products and services; and for usage analytics purposes.

The legal basis for this processing is our legitimate interest in the proper administration of our Website and business.

CCPA Categories: Identifiers; Categories Described in the Customer Records Statute

Order and Payment Information

If you purchase products from us, our payment processor will receive your credit/debit card number, security code, and expiration date; other applicable financial information; and your billing information and address. We will also receive your order and shipping details. We keep records of the products purchased along with your Contact Information and Account Information.

We process Order and Payment Information to operate our Website and business; to provide, optimize, and improve our products and services; to provide customer support; to verify and update your information; to ensure the privacy and security of our Website and operations; to authenticate your login; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to perform statistical, demographic, and marketing analyses; to administer contests, promotions, sweepstakes, offers, promotions, forms, and surveys; to communicate with you; to respond to your request; to complete transactions you request; to keep records of our communications with you; to determine user interests; to develop new products and services; for usage analytics purposes; to process and complete payments and other transactions; and to detect fraud and prevent loss.

The legal basis for this processing is our legitimate interest in the proper administration of our Website and business, the proper management of our relationships, and, where applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Commercial Information; Sensitive Personal Information

Job Applicant Information

When you apply for a job through the Website, we collect your name, email address, phone number, employment status, resume, and any other information you choose to provide.

We process Job Applicant Information to communicate with you; for recruitment and human resources purposes (including reviewing applicants for open positions and processing your application); to assess and document your qualifications for the jobs you apply for with us; for background screening and vetting; to confirm your identity and your entitlement to work; for personnel and human resources management (including ordinary business practices related to the establishment, maintenance, and termination of relationships; personnel management and administration; business management and planning; administering benefits; conducting performance reviews and disciplinary proceedings; processing employee work-related claims; and addressing labor relations issues); for the management of our operations and organization (including the establishment, performance, and management of business activities of the organization; operation, evaluation, and improvement of our recruiting system; accounting and auditing; obtaining or maintaining insurance coverage; managing risks; or obtaining professional advice); for security management purposes (including ensuring the security of our premises and information held by us as well as the safety of our personnel; preventing fraud; and network and information security); and to comply with applicable laws (including obtaining and releasing personal information as required by law; maintaining records that can include personal information, such as government identifiers, information relating to sickness, maternity or parental leave, pension and retirement; and establishing, exercising, or defending legal claims, whether in court, administrative, or other proceedings).

The legal basis for this processing is carrying out our legitimate interests in managing your potential employment, in our ongoing assessment and verification of your suitability for working with us, and in keeping records of your relationship with us as well as our legal obligations in the field of employment law. Where applicable, we also have a legitimate interest in processing taking steps to enter into an employment agreement with you.

CCPA Categories: Identifiers, Categories Described in the Customer Records Statute, Professional or Employment-related Information, Education Information, Sensitive Personal Information (social security, driver’s license, passport, or other identification number; citizenship or immigration status)

Vendor Information

In addition to Contact Information, we collect and receive information about vendors’ and potential vendors’ services, information needed to facilitate contracting, payment and tax reporting, and other information necessary to facilitate the business relationship.

We process Vendor Information to operate our Website and business; to provide, optimize, and improve our products and services; to verify and update your information; to ensure the privacy and security of our Website and operations; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to respond to your request; to complete transactions you request; to keep records of our communications with you; to process and complete payments and other transactions; and to detect fraud and prevent loss.

The legal basis for this processing is our legitimate interest in the proper administration of our Website and business, the proper management of our relationships, and, where applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Commercial Information; Professional or Employment-related Information

Cookies and Similar Technologies

The Website use cookies and similar technologies. Please see the “Our Use of Cookies and Web Beacons” section of this Notice for more information. If you choose to disable cookies and similar technologies, some areas and features of the Website may not work properly.

We process Cookies and Similar Technologies to operate our Website and business; to provide, optimize, and improve our products and services; to provide customer support; to ensure the privacy and security of our Website and operations; to authenticate your login; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience; to perform statistical, demographic, and marketing analyses; to administer contests, promotions, sweepstakes, offers, promotions, forms, and surveys; to communicate with you; to respond to your request; to complete transactions you request; to keep records of our communications with you; to determine user interests; to develop new products and services; for usage analytics purposes; to process and complete payments and other transactions; and to detect fraud and prevent loss.

Where required by law, we rely on your express opt-in consent for the use of marketing, performance, and analytic cookies and similar technologies. The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of our Website and business.

CCPA Categories: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data

Usage Data

When you visit the Website, we automatically collect information from your browser and your device, including: the date and time of your visit, data about which pages you visit, data about which links you click, information about referring websites, and your Internet Protocol (IP) address, device identifier, device type, operating system, connection information, language preferences, and browser type. On the Website where you log in, we may link this data to your Account Information to better understand your interest in our products and services.

We process Usage Data to operate the Website, to serve you the content and functionality you request, to ensure the privacy and security of our Website and operations, to develop new products and services, to enhance your experience and provide you with a more personal and interactive experience, and for usage analytics purposes.

The legal basis for this processing is our legitimate interests in monitoring and improving our Website.

CCPA Categories: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data

How Do We Collect Personal Information? We collect information (including personally identifiable information) when you visit the Website, when you provide it to us, and when you give us your permission. We also collect information about you from other sources, such as forms, profiles, surveys, quizzes, or other interactions. We combine the information we receive from third parties with information we receive from you and via your interactions with us.

Is Personal Information Required? You can visit the Website without providing any personal data. However, on some pages of the Website, we may ask you for personal data so that we may provide a service or carry out a transaction you request. Providing this information is voluntary. However, if you choose not to, we may be unable to fulfill your request or complete your transaction.

When you register with the Website or provide information to Ingram in any other manner, you agree to provide only true, accurate, current, and complete information. If you provide personal information to us about a third party, such as your friend or colleague, do so only if you received permission from that friend or colleague.

Other Processing Activities. We may also process personal information when necessary for the following:

  • Accomplishing another purpose described to you when you provide the information, for which you have consented, or for which we have a legal basis under law.
  • The establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings. (The legal basis for this processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.)
  • Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (The legal basis for this processing is our legitimate interest in the proper administration of our business.)
  • Compliance with applicable laws (The legal basis for this processing is compliance with a legal obligation to which we are subject.)
  • Compliance with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by governmental authorities and cooperation with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violate applicable law (The legal basis for this processing is compliance with a legal obligation to which we are subject.)
  • Collection, creation, use, retention, or disclosure of information that is deidentified or aggregated. We will process such data only in a de-identified fashion and will not attempt to re-identify such data.
  • Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Notice for which your personal information was provided to us.

We may process your personal information in connection with any of the purposes and uses described in this Notice on one or more of the following legal grounds:

  • Because it is necessary to perform the tasks you have requested or to comply with your instructions or other contractual obligations between you and us;
  • To comply with our legal obligations as well as to keep records of our compliance processes;
  • Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
  • Because you have chosen to publish or display your personal information on a public area of the Website, such as a comment area;
  • Because it is necessary to protect your vital interests;
  • Because it is necessary in the public interest; or
  • Because you have expressly given us your consent to process your personal information in a particular manner.

We do not use personal information for making any automated decisions affecting or creating profiles other than as described herein.

Our Use of Cookies and Web Beacons

What are First-Party and Third-Party Cookies? A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” cookie). “Session” cookies are temporarily stored on your device and remain there until they expire at the end of your browsing session. “Persistent” cookies remain stored on your device until they expire or are deleted by you. Local shared objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you are visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

What are Other “Similar Technologies”? In addition to cookies, there are other data collection technologies, such as Internet tags, web beacons, pixels, (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as you navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about your browsing, such as which advertisement, page, or publisher sent you to the receiving website.

What Cookies and Similar Technologies Are in Use and Why Do We Use Them?

Where strictly necessary.  These cookies and other technologies are necessary to enable the Website and services to provide the features you have requested, such as remembering you have logged in.

For functionality.  These cookies and similar technologies remember the choices you make, such as language or search parameters. We use these cookies to provide you with an experience more appropriate to your selections and make your use of the Website more tailored.

For performance and analytics.  These cookies and similar technologies collect information on how users interact with the Website and to improve how the Website operates. For example, we use Google Analytics cookies to help us understand how visitors arrive at and browse the Website to identify areas for improvement, such as navigation, user experience, and marketing campaigns.

Targeting cookies or advertising cookies.  These cookies collect information about your browsing habits to make advertising relevant to you and your interests. These cookies remember websites you have visited, and that information is shared with other parties such as advertising technology service providers and advertisers.

Social media cookies. These cookies are used when you share information using a social media sharing button or “like” button on our websites, or you link your account or engage with our content on or through a social media site. The social network will record that you have done this. This information may be linked to targeting/advertising activities.

How can you opt-out?

To opt-out of our use of cookies, you can use the Cookies Preferences link at the bottom of our Website. You can instruct your browser by changing its options, stopping accepting cookies, or prompting you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our Website. Ingram and our third-party partners also collect information using web beacons (also known as "tracking pixels").  You will not be able to opt-out of any cookies or other technologies that are “strictly necessary” for the Website and services.  To learn how to manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. Please note that some parts of this site may be inaccessible or not function correctly if you disable or refuse cookies.

Other Third-Party Technologies. Some third parties may use data collection technologies to collect information about you when you browse the Internet. We do not control these third parties’ technologies or how they may be used. If you have questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

Choices About Cookies. Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being stored. These settings may affect your enjoyment of the Website’s functionality. In addition, adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, you should review your web browser settings after you have changed your cookie settings. The links below provide additional information about how to disable cookies or manage the cookie settings:

You may learn more about internet advertising practices and related consumer resources at https://youradchoices.com/controlhttps://thenai.org/about-online-advertising/faq, http://www.networkadvertising.org/choices.

How Do We Disclose Personal Information? Where permitted by applicable law, we may disclose the information described above in the following contexts. We will only disclose your personal information where, when required by law, the recipient has provided written assurances that it will protect any personal information disclosed to it in accordance with applicable law. We will not share your phone number with third parties or our affiliates for the purpose of such parties sending you SMS text messages.

Category

Disclosure Contexts

Affiliates

We share personal information with our subsidiaries and affiliates and with their respective officers, directors, employees, and agents.

Corporate Transactions

We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of our company or some or all of our assets. If our business is acquired by or merged with another company, your information may be transferred to the new owners.

Disclosures with Your Consent

We will disclose your information to fulfill the purpose for which you provide it and for other purposes disclosed by us when you provide the information.

We may also ask if you would like us to share your information with third parties who are not described elsewhere in this Notice. We will only disclose your personal information in this context with your consent.

Legal Obligations and Rights

We disclose personal information in response to subpoenas, warrants, court orders, and other legal process, and to comply with relevant laws. We may also share information in order to establish or exercise our legal rights, to pursue claims, to defend against a legal claim, and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of contract.

Service Providers and Advisors

We share personal information with our and our affiliates’ contractors, service providers, insurers, and professional advisors (including attorneys, accountants, consultants, and auditors) that need access to the information to provide services on our behalf or perform functions for us.

Among other things, the recipients help us administer the Website; support our provision of services; process payments; send communications; provide technical support; support our provision of promotions, sweepstakes, or contests; and assist with other legitimate purposes permitted by law.

Deidentified or Aggregated Data

We share aggregated information and information that does not identify any specific individual, such as groupings of demographic data and preferences.

Public Forums

Any information that you disclose on public areas on the Website becomes public information. Please exercise caution when disclosing personal information in these public areas. We cannot control the actions of third parties who may view the Website and use publicly available information for their own purposes.

Advertising; Promotional Partners

We may conduct joint promotions with other companies. We may share with our advertising and promotional partners (and their service providers) certain personal information as necessary to conduct the promotion. We will not share this information with our promotional partners for any other purpose unless you consent to such sharing.

LOCATION OF PROCESSING AND INTERNATIONAL DATA TRANSFERS

Ingram is an international business, and our use of your information involves data transmission on an international basis. We have operations in the United States, and personal information may be transferred to, stored, and processed in the United States as well as other countries in which we or our, affiliates, partners, service providers, or agents maintain facilities.

By using our Website or providing us with any information, you consent to the collection, maintenance, processing, and transfer of such information in and to locations such as the United States, which may not offer the levels of protection required in other countries. 

We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information, such as express consent, when transfer is necessary for us to deliver services pursuant to an agreement, or when the transfer is subject to safeguards that assure the protection of the personal information.

HOW LONG DO WE KEEP YOUR INFORMATION?

We will keep your information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to operate our business, and to enforce our agreements.

We take reasonable steps to delete the personal information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our legal obligations or business objectives. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.

We may retain and use anonymous, de-identified, or aggregated information for as long as is permitted under applicable law.

We are required by law to maintain records of consumer requests submitted under the CCPA and how we responded to such requests for at least 24 months. We only use this information for recordkeeping purposes. For more information, please contact us via the contact information provided below.

 DATA SECURITY

We have implemented measures designed to help secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.

The safety and security of your information also depends on you. Where we have given you, or where you have chosen a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. Any user of the Website may view the information you share in public areas.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings, security measures contained on the Website, or any unauthorized access to your data.

If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

YOUR RIGHTS AND CHOICES 

Email Preferences. By establishing an account with Ingram or signing up for our email list, you agree to receive communications from us, including promotional emails, and current specials and deals. You may update your communication preferences with us at any time if you would like to alter the frequency, if available, and type of communications you receive from us, or you wish to no longer receive promotional emails from us by updating the communication preferences at the bottom of every email. If you want to receive emails from us but do not wish for us to track the emails we send you, some email services allow you to adjust your display to turn off HTML or disable download of images that should effectively disable our email tracking.

Cookies. You may manage cookies on our Website by modifying your cookie preferences, which is available when you initially access the Website and is also located at the bottom of the Website. You may also turn off all cookies (except necessary cookies) using this method. 

Is Personal Data Required? Visitors to our Website can choose not to provide personally identifiable information. In cases where personally identifiable information is needed to register for an account, you may not be able to use our services if you chose not to provide the necessary personally identifiable information.

Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Information” provided at the end of this Notice.

Updating Your Information. Our goal is to keep your information accurate, current, and complete. If any of your information changes, please let us know via any of the “Contact Information” provided at the end of this Notice.

Individual Rights. You may have certain rights relating to your personal data under local data protection laws. We honor individuals’ rights where required under applicable law, and, depending on the applicable laws, these rights may include the right to:

  • Access your personal information;
  • Know more about how we process your personal information;
  • Rectify inaccurate personal information and, taking into account the purpose of processing the personal information, ensure it is complete;
  • Erase or delete your personal information;
  • Restrict our processing of your personal information;
  • Transfer your personal information to another controller, to the extent possible;
  • Object to certain processing of your personal information;
  • Opt-out of certain disclosures of your personal information to third parties;
  • If you’re under the age of 16, or such other applicable age of consent, opt-in to certain disclosures of your personal information to third parties;
  • Not be discriminated against for exercising your rights described above; 
  • Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects; and
  • Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

All requests should be sent to the contact details noted in the “Contact Information” section of this Notice. Your personal information may be processed in responding to these rights.

European Union, European Economic Area, Switzerland, and the United Kingdom

Right of Access. You have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.

Right of Rectification. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.

Right to Erasure. In some cases, you have a legal right to request that we delete your personal information when (1) it is no longer necessary for the purposes for which it was collected; (2) consent has been withdrawn in certain instances; (3) you have objected to the processing in certain instances; (4) the personal information has been unlawfully processed; (5) the personal information has to be erased for compliance with a legal obligation; and (6) the personal information was collected in relation to the offer of information society services. However, the right is not absolute. When we delete personal information, it will be removed from our active servers and databases; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.

Right to Restrict Processing. You have the right to restrict the processing of your data when (1) the accuracy of the personal data is contested, for a period enabling the controller to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose erasure and request a restriction instead; (3) we no longer need the personal data, but you need us to keep it for the establishment, exercise, or defense of legal claims; or (4) you have objected to us processing the personal information, pending resolution of the objection.

Right to Object. In certain circumstances, you have the right to object to the processing of your personal information where the processing is necessary for performance of a task carried out in the public interest, for our legitimate interests, or for the legitimate interests of others. You also have the right to object where personal data are processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes.

Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

Right to Complain. If you believe we have not processed your personal information in accordance with applicable law, we encourage you to contact us using the contact information provided below. You may also have the right to make a complaint to an applicable Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities for residents of the EU or EEA is available at: https://edpb.europa.eu/about-edpb/board/members_en. UK residents may contact the UK Supervisory Authority here: https://ico.org.uk/make-a-complaint/data-protection-complaints/. Residents of Switzerland may contact the Federal Data Protection and Information Commissioner at https://www.edoeb.admin.ch/en/report-form-data-subjects. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.

United States

Depending on where you live in the United States, you may have certain rights relating to your personal information. We honor these rights where required under applicable law. These may include the following:

Right to Confirmation and Access. Residents of certain states have the right to confirm whether we process their personal information and to access such personal information.

Right to a Copy. Residents of certain states have the right to access their personal information, including a right to obtain a copy of the consumer’s personal information in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity without hindrance. Residents of certain states also have the right to receive a list of specific third parties to which we have disclosed the consumer’s personal data.

Right to Know. Residents of certain states have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold or shared and the categories of third parties to whom the personal information was sold or shared; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, selling, or sharing personal information; and (7) the categories of third parties to whom we disclose personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request unless a longer period is requested by you.

Right to Delete. Residents of certain states have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described herein, we will delete your personal information from our records and, as applicable, notify any service providers and contractors (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.

Right to Correct. Residents of certain states have a right to correct inaccuracies in their personal information, taking into account the nature of the personal information and the purposes for which we process the personal information. We will use commercially reasonable efforts to correct the inaccurate personal information as directed by you.

Rights Regarding Sensitive Data. We only process sensitive data with your consent or where otherwise permitted by applicable law. Where you have provided consent to this processing, you may revoke your consent or opt out of the processing of your sensitive data at any time. For residents of California, this includes your CCPA right to limit the processing of sensitive personal information to that processing permitted by the CCPA.

Right to Opt-Out. Residents of certain states have the right to direct us to stop selling, and for residents of California, sharing, your personal information to third parties and to refrain from doing so in the future. Residents of certain states also have the right to opt out of targeted advertising and profiling based on your personal information.

Submission Process. You may submit a request to exercise one of the above rights via a toll-free telephone call to 1-800-253-1560, by email to privacy@ingramcontent.com, or via our online submission form . If a request is submitted in an incorrect manner or if it is deficient, we will either (1) treat the request as if it had been submitted via the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies, as applicable.

Verification Process. We are required to verify the identities of those who submit requests to exercise certain of the above rights. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you may be required to provide your name, email address, mailing address, and/or telephone number. We will inform you if we cannot verify your identity.

  • If we cannot verify the identity of the person making a request for categories of personal information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy.
  • If we cannot verify the identity of the person making the request for specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.
  • If we cannot verify the identity of the person making a request to delete, we may deny the request.
  • If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor. In such cases we may not be required to comply with the request or may request additional information reasonably necessary to verify the request.

Authorized Agents. Authorized agents may submit requests via the methods identified in this Notice. If you use an authorized agent to submit a request to know or a request to delete, we may require: (1) the authorized agent to provide proof that you gave the agent signed permission to submit the request; (2) you to verify your identity directly with us; and (3) you to directly confirm with us that you provided the authorized agent permission to submit the request. However, we may not require these actions with respect to confirmed guardianship, conservatorship, power of attorney, or other protective arrangement in accordance with applicable law.

Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the above rights. We do not discriminate against individuals for exercising their rights under applicable law.

Appeals Process. Residents of certain states have the right to appeal a refusal to take action on a request within a reasonable time after your receipt of the decision. You may submit an appeal to a decision on your request via a toll-free telephone call to 1-800-253-1560 or by email to privacy@ingramcontent.com. We will inform you of any action taken or not taken in response to the appeal, along with a written explanation of the reasons in support of the response.

Nevada

Nevada residents may submit a verified request to us at privacy@ingramcontent.com to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law.

California

All terms used in this section shall have the meanings given in the CCPA, when applicable.

CCPA Notice at Collection. We collect and process personal information as described in the “How Do We Process Personal Data?” section of this Notice. The relevant CCPA categories for this information are indicated above. We may provide a separate notice at collection if we collect additional information or intend to use information for additional purposes.

Data Practices During the Last 12 Months. The disclosures below describe our data practices during the last twelve months:

  • Personal Information Collected. We have collected the categories of personal information listed below during the preceding 12 months:
    • Identifiers
    • Categories Described in the Customer Records Statute
    • Commercial Information
    • Internet or Other Electronic Network Activity Information
    • Geolocation Data
    • Professional or Employment-related Information
    • Education Information
    • Sensitive Personal Information
  • Categories of Sources. We have collected personal information from you, via cookies and similar technologies, and through third parties, including public sources. If you are a job applicant, this also includes background check providers.
  • Business and Commercial Purposes for Collecting. We have collected the categories of personal information listed above for the following purposes:
    • Generally:
      • Operate our Website and business
      • Provide, optimize, and improve our products and services
      • Provide customer support; to verify and update your information
      • Ensure the privacy and security of our Website and operations
      • Authenticate your login
      • Maintain our databases and back-ups; to manage our relationships with you
      • Serve you the content and functionality you request
      • Enhance your experience and provide you with a more personal and interactive experience
      • Perform statistical, demographic, and marketing analyses
      • Administer contests, promotions, sweepstakes, offers, promotions, forms, and surveys
      • Communicate with you
      • Respond to your request
      • Complete transactions you request
      • Keep records of our communications with you
      • Determine user interests
      • Develop new products and services
      • Usage analytics purposes
      • Process and complete payments and other transactions
      • Detect fraud and prevent loss
    • Job Applicants:
      • Communicate with you
      • Recruitment and human resources purposes
      • Assess and document your qualifications for the jobs you apply for with us 
      • Background screening and vetting
      • Confirm your identity and your entitlement to work
      • Personnel and human resources management
      • Management of our operations and organization
      • Security management purposes
      • Comply with applicable laws
  • Personal Information Disclosed for a Business Purpose. We have disclosed for a business purpose the categories of personal information listed below during the preceding 12 months. We have disclosed each category of personal information to the following categories of third parties: (1) subsidiaries and affiliates; (2) distribution partners; (3) advisors (accountants, attorneys); and (4) service providers and contractors (data analytics, data storage, mailing, marketing, shipping fulfillment, payment processing, Website administration, technical support).
    • Identifiers
    • Categories Described in the Customer Records Statute
    • Commercial Information
    • Internet or Other Electronic Network Activity Information
    • Geolocation Data
    • Professional or Employment-related Information
    • Education Information
    • Sensitive Personal Information
  • Business and Commercial Purposes for Disclosing. We have disclosed to the identified categories of third parties the categories of personal information listed above for the following purposes:
    • Generally:
      • Operate our Website and business
      • Provide, optimize, and improve our products and services
      • Provide customer support; to verify and update your information
      • Ensure the privacy and security of our Website and operations
      • Authenticate your login
      • Maintain our databases and back-ups; to manage our relationships with you
      • Serve you the content and functionality you request
      • Enhance your experience and provide you with a more personal and interactive experience
      • Perform statistical, demographic, and marketing analyses
      • Administer contests, promotions, sweepstakes, offers, promotions, forms, and surveys
      • Communicate with you
      • Respond to your request
      • Complete transactions you request
      • Keep records of our communications with you
      • Determine user interests
      • Develop new products and services
      • Usage analytics purposes
      • Process and complete payments and other transactions
      • Detect fraud and prevent loss
    • Job Applicants:
      • Communicate with you
      • Recruitment and human resources purposes
      • Assess and document your qualifications for the jobs you apply for with us 
      • Background screening and vetting
      • Confirm your identity and your entitlement to work
      • Personnel and human resources management
      • Management of our operations and organization
      • Security management purposes
      • Comply with applicable laws

Financial Incentives. This section explains each financial incentive and price or service difference that we may offer in exchange for the retention of your personal information so that you may make an informed decision on whether to participate.

  • Summary and Material Terms.  We provide special offers, discounts, and coupons throughout the year to individuals who share their information (for example, name and email address) with us. Participation is completely voluntary.
  • Categories of personal information implicated by the financial incentive. This program involves the following categories of personal information under the CCPA: Identifiers, Categories Described in the Customer Records Statute, and Commercial Information
  • Value[SM3] . Our financial incentives are reasonably related to the value of the data provided because we offer via email discounts on our products, and we need the email address to do so. The value of the data provided varies based on your purchases. For example, you may receive 10% off of your purchase in exchange for providing your email address to us. We have calculated this value by considering the profit generated from the incentives as well as the overall average value to us with respect to collecting the data. 
  • How to opt-in. You may opt-in to the financial incentive or price or service difference by signing up via our Website.
  • How to withdraw. You have the right to withdraw from the financial incentive at any time. You may exercise that right by contacting us using the Contact Information provided at the end of this Notice.

Notice of Right to Opt-out of Sale/Sharing. As a California resident, you have the right to direct us to stop sharing your personal information to third parties and to refrain from doing so in the future.  You may opt-out of certain targeted advertising by adjusting your cookie preferences in the Privacy Preference Center for the Website, which can be accessed within the Cookies Policy for the Website.

Limited Use of Sensitive Personal Information. We only use or disclose sensitive personal information for purposes permitted by the CCPA and to which the right to limit does not apply.

Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not discriminate against individuals for exercising their rights under the CCPA.

Other California Privacy Rights. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents who provide personal information in obtaining products or services for personal, family, or household use 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 privacy@ingramcontent.com or write us at: Ingram Content Group Attn: Legal Dept./ Privacy One Ingram Blvd. LaVergne, TN. 37086. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of the Website may make any changes to their information at any time by contacting us at privacy@ingramcontent.com.

THIRD-PARTY SITES AND SERVICES

This Notice only applies to the Website. It does not apply to any websites, applications, or services provided by third parties.

The Website may include links to, and content from, third parties. These links are to external resources and third parties that have their own privacy policies and with which we may have no relationship. It may not always be clear to you which links are to external, third-party resources. If you click on a third-party link, you will be redirected away from the Website. You can check the URL to confirm whether you have left the Website.

We cannot and do not (1) guarantee the privacy or security practices of third parties or any content provided by third parties; (2) control third parties’ independent collection or use or your information; or (3) endorse any third-party information, products, services, applications, or websites.

Any information provided by you or collected from you by a third party will be governed by that party’s privacy policy and terms of use. You should review their privacy policy and terms of use carefully.

CHILDREN UNDER THE AGE OF 18

Our Website is not for anyone under 18 years of age, and we do not knowingly collect information online from children under the age of 18. No one under 18 years of age may provide information to or on the Website or through any of its features, register on the Website, make any purchases, or use any comment features of the Website. Where data privacy laws apply, by providing any information about a person under 18 years of age on this website you confirm you received permission from the minor’s parent or legal guardian, and further agree such data will be used as specified in this Notice. If we learn that we have collected or received personal information from a child under the age of 18 online without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and to delete it.

If you believe we have information from or about a child under 18, please contact us at privacy@ingramcontent.com.

CHANGES TO THIS NOTICE

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice’s effective date. If we make material changes, we may also notify you through a notice on the Website’s homepage and/or we may send you an email regarding the updates.

You should read this Notice carefully before using the Website, and you should review it from time to time so that you are aware of its current terms. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

CONTACT INFORMATION

If you have any questions or comments about this Notice, how we collect and use your information described in this Notice, or your choices and rights, or if you wish to exercise your rights under applicable law, please do not hesitate to contact us at:

Phone: 1-800-253-1560

Email: privacy@ingramcontent.com or legal@ingramcontent.com

Mail:  

Ingram Content Group
Attn: Legal Department/ Privacy
1 Ingram Blvd.
LaVergne, TN 37086