SGS Consulting Group  (“SGS Consulting,” “we,” “us” or “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy.  This Privacy Policy describes how SGS Consulting Group may collect, use, and share the information you provide us and the information we collect in the course of operating our business, including in association with your use of SGS Consulting websites where this Privacy Policy is posted as well as any products, services software, tools, applications, features or functionality offered on or through a website or mobile application, including any SGS Consulting Clients Website provided through our websites and operated by SGS Consulting (collectively, the “Services”).  By using the Services, you acknowledge you have read and understood the terms and conditions of this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, please do not use the Services.

Your use of the Services is also governed by our Terms & Conditions.

For those who reside in California, please see section 10 of this Privacy Policy for additional information regarding our practices

1. Collection of Information

As used in this Privacy Policy, “personal information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We may collect the following categories of information from and about you:

• Identifiers, such as your name, e-mail address, phone number, and postal address;
• Demographics, such as your gender, income level, or age;
• Online activity information, such as your IP address or browsing history;
• Location information that you provide or that we collect via your device, subject to your settings;
• Inferences regarding preferences or other characteristics; 
• Transaction information, such as your password and purchase histories or tendencies;
• Payment information, such as payment card numbers;  
• Audio, electronic, visual, thermal, olfactory, or similar information, such as photographs or voice recordings;
• Professional information, such as employer or job title; and
• Education information.

We may collect personal information about you from a variety of sources, including:

• From You: We collect information that you submit to us. For example, when you use the Services, register to receive information, products or services available through the Services or interact with us in other ways, we will collect any information you voluntarily provide, and we may also request optional information to support your use of the Services. We also collect any information that you voluntarily enter into any postings, comments, or forums within the Services. If you send an e-mail to us, we will collect your e-mail address and the full content of your e-mail, including attached files and other information you choose to provide to us. If you purchase a product or service through the Services, our third-party payment processors will collect the billing and financial information they need to process your charges. This may include your postal address, email address, and financial information. 

From Your Devices:  When you use our Services, we may collect information about the devices you use to access the Services, including hardware model, operating system and version, Internet Protocol (“IP”) address and other unique device identifiers, mobile network information, and information about the device’s interaction with our Services.  We also collect information about how you use our Services, including your access times, browser types, and language. This type of data enables us to understand how often individuals use parts of the Services so we can analyze and improve them. To collect this information, we use cookies and web beacons, and other similar technologies. To learn more about how we automatically receive and record information when you interact with the Services, please see the section «Cookies, Tracking, & Third-Party Advertising” below. Note that this Privacy Policy covers only how we use information collected via cookies; it does not cover the use of such information by third parties. 

• Location Information: We may collect different types of information about your location, including general information, such as the city, state, and/or zip code associated with your IP Address, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access the Services. We may use such location information to customize the Services, including advertising that is presented to you. In order to do this, your location information may be passed along to our affiliates, agents, vendors or advertisers.
• Social Media Networks and Other Third Parties: We may obtain information about you or your use of the Services from third parties and sources, such as our vendors, like web hosting providers, analytics providers, or advertisers. You may give us permission to access your information from services offered by third parties, including social media networks. The information we obtain from third party services depends on your account/privacy settings with those third parties and the third parties’ privacy policies, so be sure to check those policies and to adjust your settings to meet your preferences. When you access the Services through social media networks and other third-party platforms, you are authorizing Sensation Brands to collect, store, and use such information and content in accordance with this Privacy Policy. Please keep in mind that any information provided to us by a third party may also be subject to that third party’s privacy policy.

2. Use & Retention of Information

We use the information we collect from you for the following purposes:

• To deliver products, services, programs, information, or newsletters, including to help us make decisions about products or promotions to offer, or to guide decisions for entering into strategic relationships;
• To process your payments;
• To alert you to special offers, updated information, and other new services or to forward promotional materials;
• To facilitate better servicing of your account by an Independent Representative;
• To fulfill the requirements of our agreements with Independent Representatives;
• To fulfill the terms of a promotion;
• To ensure the Services are relevant to your needs;
• To provide technical support and to respond to your inquiries;
• To communicate about new features;
• To protect our IT architecture and prevent fraud or potentially illegal activities;
• To enforce the terms governing use of the Services and/or to notify you of a material change to our Privacy Policy;
• To contact you in response to inquiry forms (e.g., contact forms);
• To solicit your feedback to improve your user experience;
• To facilitate and administer the services that we offer through the Services; 
• To communicate information regarding your account, and other information related to your interaction with our products or services; and
• To comply with any applicable law, regulation, legal process or governmental request.

We will retain the personal information provided for as long as it is needed to fulfill the purpose for which it is collected. 

3. Sharing and Disclosure of Information

We may disclose your information in the following circumstances:

• With your consent. We may share or disclose your information if you ask or authorize us to do so.
• Among group companies. We may share your information with our affiliated and subsidiary companies and other partners or collaborators for the purposes of processing, analyzing, or storing your information or otherwise as needed to provide the Services to you or achieve other purposes for which we collect information, in each case, consistent with the terms of this Privacy Policy.
• With service providers. We engage service providers to perform a variety of services and functions for us, such as data storage, order fulfillment, transmitting emails, and managing digital content. We may share your information with such service providers subject to confidentiality obligations consistent with this Privacy Policy.
• To comply with legal requirements and to protect you, us, and others. Notwithstanding anything to the contrary in this Privacy Policy, we reserve the right to retain and disclose your information at our discretion if we believe in good faith that such retention and disclosure is necessary to: (i) comply with relevant laws or to respond to subpoenas, warrants, or similar process served on us; (ii) protect and defend our rights or property, you, or third parties; or (iii) ensure the safety and security of our Services, systems, and of our customers and third parties.
• In connection with a business transfer: In the event we go through a business transition such as a merger, acquisition by another company, bankruptcy, reorganization, or sale of all or a portion of our assets, your information may be sold or transferred as part of that transaction. You acknowledge that such transfers may occur and are permitted by this Privacy Policy and that the new entity may continue to process your information as set forth in this Privacy Policy.
• If the information has been aggregated, de-identified, or otherwise does not identify you personally: We may share or disclose information that has been aggregated, de-identified, or otherwise does not identify you or information that you choose to make public. This Privacy Policy does not limit our use or disclosure of de-identified information (i.e., information from which your name and any other personally identifying information has been removed) in any way, and we reserve the right to use and disclose such information to our partners, advertisers, and any other third parties at our discretion. 

If you do not agree or do not consent to the disclosure of your information in any manner described above, you should not use the Services or interact with us.

We may disclose the following categories of personal information for our business purposes:

• Identifiers;
• Demographics;
• Online activity information;
• Location information;
• Inferences regarding preferences or other characteristics;
• Transaction information;
• Payment information; 
• Audio, electronic, visual, thermal, olfactory, or similar information;
• Professional information; and 
• Education information.

We may disclose certain personal information in exchange for services, insights or other valuable consideration.  California law treats such sharing as a “sale” even if no money is exchanged. These disclosures may involve:

• Identifiers;
• Demographics;
• Online activity information;
• Location information;
• Inferences regarding preferences or other characteristics;
• Transaction information (not including payment card numbers);
• Audio, electronic, visual, thermal, olfactory, or similar information;
• Professional information; and 
• Education information.

4. Collection and Use of Information from Children

The Services are not intended for children.  We do not knowingly collect personal information from children, and the Services are not designed to attract children.  In the event that we learn that a child under the age of 16 has provided personal information to us, we will delete or destroy such personal information as soon as possible.

5. Notice of Public Posting Areas

Please note that any information you include in a message you post to any chat room, forum, blog, or other public posting area is available to anyone with Internet access. If you do not want people to know your email address, for example, don’t include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS, BLOGS, AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS, BLOGS, AND OTHER PUBLIC POSTING AREAS.

6. Third-Party Links

When you use the Services, there may be links and you may be directed to third-party websites.  We are not responsible for the privacy practices or content of such other sites. If you have any questions about how these other sites use your information, you should review their policies and contact them directly.

7. Access and Opt-Out

In the event you have an account with us, you may utilize that account to access your personal information to ensure it is correct, accurate, and current. To edit, modify, or delete your information, please contact us using the contact information provided below. We will manage deletion requests in accordance with the law and our record retention policy.

We communicate with users who subscribe to our services on a regular basis via email. For communications that are promotional in nature, we provide you the opportunity to exercise an opt-out choice if you do not want to receive these other types of communication from us, such as emails or updates from us regarding new services and products offered on the Services. The opt-out choice may be exercised by ticking the appropriate box if such checkbox is available at the points where personal information is collected or by contacting us. We will process your request to unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until your request to unsubscribe is processed. You also may opt out of receiving such emails by clicking on the “unsubscribe” link within the text of the email.

8. Security 

We implement reasonable security measures to ensure the security of your personal information.  Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure.  Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk.  We recommend that you take additional measures to protect yourself, including by installing anti-virus software, closing browsers after use, keeping confidential your passwords, and making sure that you regularly update software and apps. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services or otherwise providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services.  We may post a notice via the Services if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

9. International Data Transfers 

We are based in the US. If you choose to provide us with information, please understand that your personal information may be transferred to the US and that we may transfer that information to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. We put in place appropriate operational, procedural, and technical measures in order to ensure the protection of your personal information. You acknowledge you understand that by providing your personal information: (i) your personal information will be used for the uses identified above in accordance with this Privacy Policy; and (ii) your personal information may be transferred to the US and other jurisdictions as indicated above, in accordance with applicable law.

10. Your California Privacy Rights 

California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below and put “Expose The Light” in the subject line of your request.

Additionally, our customers that are California consumers have the following rights. To the extent that these rights apply to you, the following rights are provided:

• Right to know. You have the right to know and request information about the categories and specific pieces of personal information we have collected about you within the last 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal information. 
• Right to delete. You have the right to request the deletion of your personal information, subject to certain exceptions. 
• Right to opt-out. You have the right to opt out of certain disclosers of your personal information for valuable consideration.
• Right to non-discrimination. You have the right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information. 

If you would like to exercise one or more of the rights above, please contact us using the contact information provided below. You may designate an authorized agent to make a request on your behalf. Such authorized agent must be registered with the California Secretary of State. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

We may need to confirm your verifiable consumer request before completing your request, and, for example, may ask for you to confirm data points we already have about you. We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.

11. Cookies, Tracking, & Third-Party Advertising 

We use cookies, tags, and beacons on our Services in order to offer you a full range of functions and to make the use of our Services more convenient for you. Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the website or a third party to recognize you and make your next visit easier and the website more useful to you. Pixel tags are electronic images that may be associated with cookies.  Specifically, we utilize cookies and tags like Javascript, server logs, Facebook pixel, and Google Analytics cookies. The Google Analytics opt-out policy is available here: 

https://support.google.com/analytics/answer/2700409?hl=en

We do not respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how in this Privacy Policy.

12. Changes to This Privacy Policy

We reserve the right to change this Privacy Policy from time to time. If we make material changes, we will notify you by placing a prominent notice on the Services and/or by sending you an email at the email address we have on file for you. We encourage you to periodically review this Privacy Policy to keep up to date on how we are handling your personal information.

13. Contact Us 

If you have any questions, comments, or concerns about our privacy practices or this Privacy Policy, or to exercise any of your rights, please contact us at:

contact@sgsconsulting.net

1 302-219-08 60