Privacy Policy

This Privacy Policy (the "Privacy Policy") explains how we collect, protect, use, and disclose the personal information (defined below) when you use our website located at www.Bulkitrade.com or any other website we operate, including without limitation those websites, applications, web pages or applicable interactions such as any contact through which our customers, suppliers, associates, contractors and business partners may complete transactions, conduct other business and manage their accounts (collectively the "Sites"). We understand that you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about this Privacy Policy.

Bulkitrade is a proprietary, web-based application through which we provide the products and services of our affiliated contractors, distributors, and other associated partners to retail markets in the United States and select international markets. Our mission is to offer a best-in-class platform for opening, facilitating and supporting access to new and emerging markets to our brand partners, while similarly providing a viable, effective and efficient sourcing tool to our selected retail communities.

This Policy is an enterprise-wide policy and shall apply to Bulkitrade and Bulkitrade subsidiaries' and affiliates' owned and managed websites and applications.

Compliance to privacy and data protection regulations such as the General Data Protection Regulations (GDPR) or the California Consumer Privacy Act (CCPA) requires Bulkitrade to explain how we collect, protect, use and disclose Personal Information (defined below in the Definitions section) when visitors use our Sites and applications.

HOW BULKITRADE COLLECTS PERSONAL INFORMATION

Bulkitrade may collect personal information from its customers, suppliers and other Site users in several ways:

• Bulkitrade may gather account information through the Sites;
• Bulkitrade may gather customer information through the Sites;
• Bulkitrade may maintain historical account information of its customers and suppliers;
• Bulkitrade may gather information about individual payors and guarantors;
• Bulkitrade may gather information from the Sites by cookies and similar Internet monitoring technologies; and
• Bulkitrade may in some instances gather information from third parties, for example but without limitation, when a customer completes a purchase with Bulkitrade through a third-party website.

WHAT PERSONAL INFORMATION BULKITRADE COLLECTS

The categories of personal information we may collect through the Sites, use, and disclose for a business purpose as described below are as follows:

• Personal identifiers for employment applications or business credit applications, such as a real name, alias, postal address, unique personal identifier, IP address, email address, account name, social security number, driver's license number, national insurance number, passport number, or other similar identifiers;
• Personal identifiers for processing transactions, such as name, email address, shipping address, phone number, payment card information, and information about transactions including purchase information and pick-up times and locations;
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Internet or other electronic network activity information, including browsing history, search history, and information regarding a California resident's interaction with an internet web site, application, or advertisement;
• Geolocation data;
• Audio, electronic, visual or similar information;
• Professional or employment-related information; and
• Education information for employment purposes.

Cookies are small text files stored by your browser in your computer when you visit our Sites. We and outside companies, such as advertising networks, social media widgets, and analytics providers, use cookies and similar technologies (e.g., web beacons and web server logs) to provide and improve the Sites and our emails and make them easier to use. The information collected in this manner may include IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, pages visited, and other information about the usage of our Sites or emails. The technology permits us to recognize users and avoid repetitive requests for the same information. The technology also assists us in identifying the types of browsers and operating systems used most by our customers, and how visitors move through the Sites. All this information enables us to improve the Sites and related communications, generally but without limitation for efficiency/speed and practicality of use, and for purposes of tailoring them to our customers' needs, usage and preferences. We may also use this technology to track user trends and patterns in order to better understand and improve areas of our Sites that our users find valuable.

We also reserve the right to use outside companies to display ads on our Sites. These ads may contain cookies. Cookies received with banner ads are collected by such outside companies, and we do not have access to this information. These outside companies also may collect and combine information collected on our Sites and emails with other information about your online activities over time, on other devices, and on other websites or apps, if those websites and apps also use the same partners.

We currently use programs such as Google Analytics to collect and process certain Site usage data. To learn more about Google Analytics and how to opt out, please visit https://policies.google.com/technologies/partner-sites. You may be able to change browser settings to block and delete cookies when you access our Sites through a web browser. We respect your right to do so, but please note that in the event of such activity, our Sites may not work properly or most efficiently. Our Sites do not respond to browser do-not-track signals.

You may be able to opt out of receiving personalized advertisements on this browser or device from advertisers, or other advertising networks who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to those websites are as follows:

• Network Advertising Initiative: http://www.networkadvertising.org/choices/
• Digital Advertising Alliance: http://www.aboutads.info/choices/

When you opt out of personalized advertising, you may continue to see online advertising on the Sites and/or our ads on other websites and online services.

Bulkitrade may provide third parties with personal information for our business purposes to provide or improve our products and services, including to deliver products at your request, or to help Bulkitrade market to consumers. When we do, Bulkitrade requires those third parties to handle such information in accordance with relevant laws and in a manner that is consistent with this Privacy Policy. Subject to applicable laws, Bulkitrade also reserves the right to share, for Bulkitrade's own business purposes, personal information with companies who provide services such as information processing, associate benefits processing and services, banking/financial services, extending credit, fulfilling customer orders, delivering products, managing and enhancing customer data, providing customer service, assessing interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information, are not permitted to use personal information other than for purposes of providing services to us and may be located wherever Bulkitrade operates.

Personal information is used to complete and support your use of the Sites and the services provided thereon and to comply with any requirements of law. Bulkitrade may share personal information with third parties as described below:

• Bulkitrade may disclose personal information as required by law and for your protection, Bulkitrade's protection, and the protection of others.
• Bulkitrade may disclose personal information, subject to confidentiality restrictions, as part of a contemplated or actual corporate transaction, financing, or sale of the assets of a relevant business unit.
• Bulkitrade reserves the right to allow other users of the Sites to browse comments, questions or other entries that you have submitted or commented on in one or more forums, message boards, product ratings, feedback portals or other interactive or social aspects that Bulkitrade may include on the Sites from time to time. Note that any such disclosures may be publicly available to any visitor to the Sites, and, in addition, Bulkitrade may choose to post this data on other platforms publicly in the future. Your use of such social features constitutes your consent and agreement to Bulkitrade's use of any content you post or transmit through such features for Bulkitrade's editorial, advertising and publicity purposes, without compensation to you, except where prohibited by law. Please see the applicable portions of our Web Site Use Policy for more information regarding your applicable consent and permissions granted to Bulkitrade.

Bulkitrade takes the security of your personal information seriously. We strive to process your information securely, in accordance with this Privacy Policy and in accordance with the information security requirements defined by applicable law. We cannot, however, be responsible for Internet communications that are inherently not completely secure.

INTERNATIONAL TRANSFERS

Personal information collected on the Sites may be stored and processed in the United States or any other country in which Bulkitrade or its affiliates, subsidiaries, agents, or third-party service providers maintain facilities and/or infrastructure, and by using the Sites, you acknowledge that such transfers of information outside of your country to the extent permissible under applicable law occur.

LAWFUL BASIS FOR USING PERSONAL INFORMATION

We use the personal information you provide to us (either orally, in writing, through your use of our website, or as a result of our dealings with you) and any data we obtain from third parties to provide the service requested by you.

We recognize that we have a legitimate interest in processing the personal data we collect about you for a number of reasons, including, but not limited to: marketing purposes, to enable us to enhance, modify, personalize, or otherwise improve our services, identify and prevent fraud, enhance and protect the security of our network and systems, and market research. "Legitimate interests" means the interests of our business in conducting and managing our business to enable us to give you the best service and most secure experience.

When we use your information for our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. Where applicable, legitimate interest assessments are conducted to ensure that these rights are protected.

PRIVACY RIGHTS

You may inform us of any changes in your personal information, and in accordance with our obligations under applicable data protection laws we will update or delete your personal information accordingly.

You may have the right to: (a) Request access to your personal information we hold about you; (b) Request that we correct an inaccurate persona information we hold about you; (c) Request that we delete any personal information we hold about you; (d) Restrict the processing of personal information we hold about you; (e) Object to the processing of personal information we hold about you; and/or (f) Receive any personal information we hold about you in a structured and commonly used machine-readable format or have such personal information transmitted to another company. If you would like to exercise any of your rights, please contact compliance@Bulkitrade.com.

RETENTION OF YOUR PERSONAL INFORMATION

We will hold your personal information in accordance with the applicable principles of the GDPR (and associated legislation) and for as long as reasonably necessary to fulfil the purposes for which it was collected. We may obtain your data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you. We are obliged and permitted by law and regulation to retain certain types of data for a minimum period. The minimum period tends to be for six years but can be longer if the statute or regulation requires.

The California Consumer Privacy Act of 2018 (CCPA) went into effect on January 1, 2020. The CCPA grants certain California residents five new rights respecting their personal information. If you are a California resident, you may have the following rights:

• The right to request more information about Bulkitrade's data collection and sales practices in connection with your personal information, including the categories of personal information Bulkitrade has collected, the source of the information, Bulkitrade's use of the information and, if the information was disclosed or sold to third parties, the categories of personal information disclosed or sold to third parties and the categories of third parties to whom such information was disclosed or sold;
• The right to request a copy of the specific personal information collected about you during the 12 months before your request (together with right set forth in the foregoing Section (1.), a "personal information request"). You may only make a personal information request twice in a 12-month period, and Bulkitrade will respond within 45 days of receiving a personal information request;
• The right to request that personal information be deleted (with certain legally permitted exceptions);
• The right to request that your personal information not be sold to third parties, if applicable; and
• The right not to be discriminated against because you exercise any of the foregoing rights.

Bulkitrade does not rent, sell, or share personal information (as defined by California Civil Code §1798.83) about you that we collect on the Site with other people or unaffiliated companies for their direct marketing purposes, unless we have your permission, and Bulkitrade has not "sold" (as that term is defined in the CCPA) your personal information in the last 12 months

Note that, in connection with the exercise of the above rights, Bulkitrade may need to collect information from you so that Bulkitrade can verify your identity.

You may exercise these rights by contacting us. Please go to the REPORTING & INVESTIGATIONS below for additional information.

Bulkitrade's Sites are not directed to children under the age of 13 and do not knowingly collect personal information from children under the age of 13. Notwithstanding the foregoing, please note that we expressly do not authorize users under the age of 18 to use our site.

Please use the Contact Us email below if you have concerns regarding the potential collection of your child's information.

US AND NON-EEA REQUEST

If you believe that Bulkitrade has not adhered to this Privacy Policy, or if you feel that you need to correct information about you held by Bulkitrade, please contact Bulkitrade by email at compliance@Bulkitrade.com or by postal mail at Bulkitrade Inc., Attn: Compliance, C/O Legalinc Corporate Services, Inc., 651 N Broad Street, Ste. 206, Middletown DE 19709. Additionally, an individual privacy right request can be made by visiting our web page at www.Bulkitrade.com.

EEA

To exercise any of your rights in connection with your personal information, please contact compliance@Bulkitrade.com. We will process any request in line with applicable local laws. You additionally have the right to lodge a complaint about how we process your personal information with the supervisor authority in your country.

Associates may immediately report any known or suspected violations of this Policy. To do so, please contact us directly at compliance@bulkitrade.com, or submit a report via our website at www.bulkitrade.com . Any such report will be kept confidential, and anyone reporting a suspected or actual violation of this Policy in good faith will be protected from retaliation under Bulkitrade's applicable policy and codes of conduct. You must cooperate with all investigations of alleged Policy violations.

By using any of the Sites, you agree to this Privacy Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version, provided that as to any given personal information we will abide by the terms of the Privacy Policy in effect when we collected that personal information, absent your express consent. We may change this Privacy Policy at any time by posting a new version of this Privacy Policy on the Sites. If we make any material changes, we will let you know through the Sites, by email, or other communication. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal information we collect.

Personal Information: Personal information is generally data that relates to a single identifiable person.

You may be asked to provide your personal information when you are in contact with Bulkitrade or a Bulkitrade affiliated company and when you interact with Bulkitrade's Sites. Bulkitrade and its affiliates may share this personal information and use it consistent with this Privacy Policy. Bulkitrade may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Business Customer: An entity who has entered into a prime contract with Bulkitrade or a subsidiary to provide business services and/or product.

EEA: European Economic Area

Associate: Person who is employed by Bulkitrade or a subsidiary -otherwise identified as an employee.