Last Updated: January 1, 2024

JLM Systems and its affiliates and subsidiaries (including Tacmor®, ThrottleWeb™, TheAdCampaign, JamesMarcey, CamoGear®, and other brands) ("JLM Systems," "we," "us," "The Company") respect the privacy of our clients’ families and website visitors. We value our relationships with existing and prospective clients ("you"), and recognize that an essential element of those relationships is the trust and confidence you place in us to maintain that privacy over the course of the relationship.

California Notice: California residents can learn more about our information practices by visiting our California Privacy Notice here.

Virginia, Connecticut, and Colorado residents can learn more about their privacy rights here.

This Privacy Policy applies to the Personal Information you provide to us or that we obtain on our websites and any mobile applications linking to this Privacy Policy ("Sites") and to the Personal Information you provide to us or that we obtain from you in person at one of our locations or other locations, by phone, and by mail. This Privacy Policy does not apply to Personal Information that you submit to websites belonging to our business partners or any other third parties or to any Personal Information that our business partners or third parties collect from you through the Sites, even if those third-party websites are linked to our Sites.

Personal Information. "Personal Information" means information that identifies, relates to, is reasonably capable of being associated with, or describes, directly or indirectly, a particular individual, such as: name, address, email address, or phone number.

User-Generated Content. This Privacy Policy does not apply to information you post online that is viewable to the public. When you post any information or other content to a public online blog, guestbook, or review using our Sites or when you post information on any JLM Systems social media page, such information and/or other content is viewable to anyone on the Internet. We urge you to be very careful when deciding to disclose your personal data, or any other information, on our Sites. This Privacy Policy does not apply to such publicly posted information.

Information We Collect and How We Collect It
Information You Provide. We may collect and store the following Personal Information when you submit it: (1) through our Sites; (2) in person at one of our locations permanent, or temporary; (3) at an informational trade show seminar we conduct; (4) by phone; or (5) by mail. We may use this information for typical business purposes (including auditing our interactions with our clients or Site visitors, for internal reporting purposes, or security and anti-fraud purposes) and as described more specifically below:

Personal Identifiers. We receive personal identifiers that you provide to us (such as your name, address, phone number, email address, billing address, shipping address, date of birth, and in certain instances, insurance policy number, signature, and social security number) and use them to respond to your requests; to create new member accounts at your request; to fulfill your orders for merchandise and services;  to communicate with you for marketing and informational purposes (you may opt out of receiving marketing emails from us at any time by using the unsubscribe link located in emails or on the websites); to provide you with the products and services you request from us pursuant to the terms of purchase; and to provide you with information about our products and services that you request from us. We will also create a client order number when you make a purchase so that we can identify you.

• Message Content. We collect the messages you submit to us through contact, sign-up, and purchase forms on the Sites, such as customer service requests, messages you would like us to provide to delivery recipients, and delivery instructions. We use this information to respond to and fulfill your requests, and to improve our Sites and our service and merchandise offerings.
• Audio and Visual Information. We receive any digital photographs and audio files you submit through the Sites. We post this information to public areas of the Sites at your direction. Additionally, at those locations where we employ surveillance cameras in public areas for security purposes, we may collect images of you for security and access control purposes.
• Financial Information. We receive financial information (such as payment card and bank account information) to process payments for merchandise and services you purchase on the Sites. We do not store your payment card information. We may also collect your credit-related information such as credit scores, or other financial information when we assist with financing. We may collect your financial information from any contract with us that you sign, from processing or administering your financial transactions, and occasionally, from credit reporting or collection agencies.
• Commercial Transaction Information. We collect and generate commercial transaction information (such as records of merchandise and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) when you make purchases on the Sites. We use this information to fulfill your orders, to improve our service and merchandise offerings, to tailor our marketing efforts, and for internal reporting purposes. We may also use this information internally to create records of your consuming history for audit purposes and in order to fulfill the terms of purchase contracts you enter into with us, and as required pursuant to state laws regarding products purchased.
• Geo-Location Information. Some of the information we collect, such as Internet Protocol ("IP") addresses, may be used to estimate an approximate location of the device you are using to access our Sites in order to enhance and personalize the features and functionality of our Sites, including our mobile applications, and service offerings.
• De-identified or Aggregated Information. We may de-identify or aggregate data and may use and disclose it for any business purpose.
• Inferences Drawn from Personal Information. We may use the information you provide to create a profile about your preferences to offer you products and services in which we think you might be interested.
• Characteristics of Protected Classifications under State or Federal Law. To the extent permissible under applicable law, we may collect your age, gender, ethnicity, religion, and veteran status for the purposes of providing you products and determining your service preferences and in order to market products and services we think would be of interest to you.

Information We Collect From Business Partners. We may receive some of the personal identifiers, message content, and commercial transaction information listed above from third-party business partners related to your transactions with them that involve us providing you with merchandise or services. The Sites may also permit you to log-in and connect to the Sites with your social media account (such as Facebook), and we collect profile information about you from that social media website that you have made publicly available. We use this profile information for the same purposes as when we receive the information directly from you, as described above.

Information Collected Automatically Through the Sites. Like many website operators, when you access and use our Sites, we use cookies, log data, and similar technology to automatically record personal identifiers (such as your IP address and device identifiers), information about your device (such as your browser type, locale preferences, and mobile carrier) and information concerning your usage activity on the Sites (such as your interaction with our Sites, the link you used to reach our Sites, and content displayed on our Sites and on other websites and online services). We use the data to enable certain features of our Sites, preserve your preferences and customize your experience when you visit and return to the Sites, and to study, enhance and improve the use and capabilities of our Sites, content, and advertising.

• Cookies: A "cookie" is a small data file that we transfer to your browser or mobile device. Most browsers provide controls allowing you to block receipt of cookies, to delete cookies, or to be prompted before cookies are received. Please note that, if you delete or choose not to receive cookies from our Sites, the functionality of the Sites may be impaired. To find out more about cookies, including how to manage or delete them, visit www.allaboutcookies.org.
• We use third-party advertising services to serve advertisements on our behalf when you visit some of our Sites and other websites, third-party email services to send informational and marketing email to you, and third-party analytics services to help us understand and improve the usage of our Sites and the effectiveness of our marketing efforts. In some situations, we permit the companies providing these services to set and access cookies (and use similar data tools, such as "pixel tags" or "web beacons") through our Sites and our emails, and these companies may collect, for example, your personal identifiers (such as IP address, device and browser identifiers and characteristics, and anonymous identifiers) and information about your device (such as operating system and language preferences) and your usage activity on the Sites (such as your interaction with our Sites, the link you used to reach them, and the content and advertising displayed on them and our content and advertising on other websites and online services) and use this information to provide advertisements about goods and services of interest to you on our Sites and other non-affiliated websites and/or to provide analytical information for our Sites. Third-party companies also may collect and combine information about your online activities over time, on other devices, and on other websites or online services, if those websites and online services also use the same companies. Information about cookies and similar technology placed by third-party companies on our Sites and their related data practices is set forth below.

Analytics and Advertising Technologies
Our Site uses analytics technology to understand how users interact with the Sites, improve our web experience, and better market our products. Analytics services in use on our Site include Google Analytics. These analytics services use cookies and other tracking technologies to collect information about how you use the Sites. Personal Information collected by these analytics services (e.g., your IP address and other usage information) may be transmitted to and stored on servers in the U.S. (or elsewhere). See below for more information on your choices regarding analytics services.

You may choose not to receive some interest-based advertising by submitting opt-outs. Some of the advertisers and business partners that perform advertising-related services for us may participate in the Digital Advertising Alliance’s ("DAA") Self-Regulatory Program for Online Behavioral Advertising and/or the Network Advertising Initiative ("NAI"). To learn more about how you can exercise certain choices regarding interest-based advertising, including use of cross-device data for serving ads, visit http://www.aboutads.info/choices/. To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please remember that 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.

Google Analytics
Our Sites use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with the Sites, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The information generated by Google Analytics is subject to Google’s privacy policies, available here.

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.
We also use advertising services provided by Google Ad Services. To learn more about the data Google collects for advertising and to opt out of certain ad targeting by Google, please visit here.

Online Tracking / Do-Not-Track Signals
Your web browser may have settings that allow you to transmit a "Do Not Track" signal when you visit various websites or use online services. Like many websites and online services, our services are not designed to respond to "Do Not Track" signals received from browsers. For more information about Do-Not-Track, please visit http://www.allaboutdnt.com.

Retention of Personal Information
We will retain your Personal Information for as long as is necessary to fulfill the purposes for which it was collected, as set out in this Privacy Policy, unless a longer retention period is permitted or required by law. We will also retain your Personal Information as required to fulfil our legal obligations, resolve disputes, and enforce our legal agreements and policies. We may also retain Site usage data to improve the functionality of our Sites, and destroy such data in accordance with our internal retention polices.

Protecting Personal Information
We employ reasonable security measures to secure and protect the information we receive. Please remember, though, that no method of electronic transmission or storage is 100% secure.

How We Share Personal Information
We may provide business partners, affiliates, and third parties with the Personal Information we collect (as described above) for our business purposes to assist us in providing products and services to you, including to process transactions, deliver products at your request, or to help us market products and services to you. We also disclose Personal Information as described below:
To Provide, Protect, and Improve Our Sites, Merchandise, and Services. We disclose Personal Information as necessary to operate our business, such as to third-party service providers and affiliates in connection with providing services to you or processing your transactions. For example, we may provide your name, telephone, and address information, and a redacted credit card number to vendors, such as distributors, shippers and manufacturers, to complete a transaction you have requested or otherwise at your direction. We require that those providers use Personal Information only for that purpose, and we also require assurances that they will appropriately protect Personal Information entrusted to them. We also may access, preserve, and disclose information if we believe that such action is necessary in our judgment to protect and defend our rights or property, or those of others. For example, we may provide information, including IP address information, to our service providers to protect the Sites, such as for fraud detection purposes.

To Comply with the Law and Legal Process. We may access, preserve, and disclose your Personal Information if required to do so by law or if we believe that such action is necessary in our judgment to comply with a legal obligation.

Other Sharing. We may share information as described above for other business purposes as otherwise explained in this Privacy Policy.

Sales, Mergers, and Acquisitions. In the event of, or during negotiations of any proposed or actual merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, joint venture, assignment, or transition of service to another provider of one or more locations or business units (whether by private sale, through operation of law, as part of a divestiture plan, or otherwise), we will provide Personal Information and transaction history associated with each such business unit to the persons and/or entities assuming control of such business unit or as otherwise necessary to complete the transaction as permitted by law or contract. To the extent permissible by law, we will require any such persons and/or entities to treat such Personal Information consistent with the applicable provisions of this Privacy Policy.

Social Features on Our Sites
Information You May Share with Social Networking Websites. The Sites may provide options allowing you to share information with social networking websites, such as Facebook. Their use of the information you share will be governed by their privacy policies, and we are not responsible for how they treat the information.

Public Disclosure Using Non-Restricted Services. Our Sites make online Reviews and Comments, Guest Books, Photo Galleries, other online services, and other postings to our public services available for viewing by all our visitors unless the sponsor or host of a service selects a privacy setting that restricts public access (available as an option only on certain services). As stated above, when you post any information or other content to the public areas of the Sites, such information is viewable by the public. This public information may be collected and used by others without your or our knowledge, and the security and other protective provisions of this Privacy Policy do not apply. Also, please keep in mind that publicly posting your user ID or contact information may result in the transmission of unsolicited messages to you from persons and entities over which we have no control. Please exercise caution and good judgment when disclosing any Personal Information to any public services. Note that we cannot be responsible for any online postings by a family member, friend, acquaintance or other person or entity outside of our control. Such activities and the associated postings are also outside the scope of this Privacy Policy. If you provide any information or images to us for public disclosure, you represent that you have permission to provide that information or images and that such information or images may be indexed by search engines.

Links
The Sites may contain links to other websites, and other websites may link to the Sites. Please be aware that we are not responsible for the privacy practices of such other websites. Whenever you visit another website – via a link from the Sites or otherwise – you should review the privacy policy of that other website. This Privacy Policy applies solely to information provided or obtained on our Sites.

No Use by Children Under the Age of 18
The Sites are not intended for use by children under the age of 18. If you are under the age of 18, you may not use our Sites. If a parent or legal guardian posts an entry on behalf of a child under the age of 18 on an online guestbook or other section of the Sites, the parent or legal guardian must indicate that such entry is being made on behalf of the child by the parent or legal guardian. Caution and good judgment should be used in connection with any information provided concerning the child. We do not knowingly collect, maintain, or use Personal Information from children under 18 years of age. If we believe that any information has been posted by a child under the age of 18, we will promptly delete that information. Parents may contact us using the methods set forth below to request that information concerning their child be removed from our Sites.

International Users
We store your Personal Information in our offices and with our service providers in the United States. While your Personal Information is in the United States, it is subject to United States laws, and may be subject to disclosure to the governments, courts, law enforcement, or regulatory agencies in the United States, pursuant to applicable laws. By providing your information and using the Sites you consent to any transfer and processing in the United States in accordance with this Privacy Policy.

Privacy Rights
Certain jurisdictions impose specific legal requirements and grant privacy rights with respect to Personal Information, and we will comply with restrictions and any requests you submit as required by applicable law. You may be able to use the Sites to access and update the information that you have provided to us through your use of the Sites or otherwise.

California Privacy Rights
California residents can learn more about their privacy rights at California-privacy-notice.

Nevada Privacy Notice
Nevada law allows residents to opt out of the sale of certain Personal Information, called "covered information." We do not sell covered information as defined under Nevada law and we have no plans to change that practice. If you want to be notified if we do change that practice, you may submit your request by emailing us at privacy@throttleweb.com.

Virginia, Colorado, Connecticut and Utah Privacy Rights
This section applies to Virginia Consumers as defined by the Virginia Consumer Data Protection Act ("VCDPA"), Colorado Consumers as defined by the Colorado Privacy Act ("CPA"), Connecticut Consumers as defined by the Connecticut Data Protection Act ("CTDPA"), and Utah Consumers as defined by the Utah Consumer Privacy Act that use our services. Capitalized terms defined in the VCDPA, CPA, CTDPA, and UCPA that are used in this section shall have the same meaning as in the VCDPA, CPA, CTDPA and UCPA.

This section describes our collection, use, and disclosure of Personal Data. You can learn more about the Personal Data we Process and the purpose for processing such Personal Data in the section above. You can also learn more about our disclosure of Personal Data and the categories of Third Parties we disclose Personal Data to in the How We Share Personal Information section above.

If you are a Virginia, Colorado, Connecticut or Utah Consumer, subject to certain conditions and restrictions set out in the VCDPA, CPA, CTDPA, UCPA and other applicable laws, you have the following rights with regard to your Personal Data. Please note that we will need to authenticate your identity before your request can be processed. For authentication we will match the Personal Data you provide against our records.

1. Right to Access. You have the right to know the Personal Data that we may hold about you and access such Personal Data.
2. Right to Delete. You have the right to request that we delete Personal Data that we have Collected from or obtained about you.
3. Right to Opt-Out of Sales. You have the right to opt-out of the Sale of Personal Data. We do not Sell your Personal Data as defined under the VCDPA and UCPA, however, some of our advertising practices may be considered a "Sale" under certain state privacy laws, such as the CPA and the CTDPA. If you are a resident of Colorado, Connecticut, you can opt out of the "Sale" of your Personal Data, which may overlap with your right to opt out of Targeted Advertising.
4. Right to Opt-Out of Targeted Advertising. You may request that we stop disclosures of your Personal Data for Targeted Advertising by clicking on the "Do Not Sell or Share My Personal Information" link in the footer of our Sites where we engage in such practices and manage your cookie preferences.

If you are a Virginia, Colorado, or Connecticut Consumer, subject to certain conditions and restrictions set out in the VCDPA, CPA, CTDPA and other applicable laws, you have the following rights, in addition to the rights stated above, with regard to your Personal Data.

1. Right to Correct. You have the right to request that we correct inaccuracies in your Personal Data.
2. Right to Opt-Out of Profiling. You have the right to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects. Because we do not engage in profiling that would result in decisions that produce legal or similarly significant effects, we do not offer this right.
3. Right to Appeal. If you are unsatisfied with our actions related to the exercise of one of your privacy rights above, you may appeal our decision using our online form
4. We may Sell or share the categories of Personal Data listed below to our advertising partners:

• personal identifiers
• geo-location information
• information collected automatically through our Sites (e.g., IP addresses and device identifiers)

We also Process the following categories of Personal Data: personal identifiers, geo-location information, and information collected automatically through our Sites for Targeted Advertising. You have the right to opt-out of the Processing of your Personal Data for Targeted Advertising, as described below.

Virginia, Colorado, Connecticut and Utah Consumers may submit their requests under their respective state laws here https://www.throttleweb.com/en-gb/information/multistate-consumer-rights-request-form. Please note that, depending on the nature of your request, you may be asked to provide information to verify your identity before your request can be Processed. You may exercise your privacy rights under the VCDPA, CPA, CTDPA and UCPA no more than twice in a 12-month period. If you choose to exercise any of the privacy rights described above, you will not receive discriminatory treatment from us.

Notification of Changes to Privacy Policy
We reserve the right to modify this Privacy Policy. Whenever we decide to update this Privacy Policy, notice of the change will be indicated by the "Last Updated" date at the top of this Privacy Policy. Nevertheless, you should review the Privacy Policy from time to time to be sure you are aware of the most recent version. Your use of the Sites after any update to this Privacy Policy will constitute your acceptance of the changes. Please be assured that we will only use Personal Information in accordance with the Privacy Policy in effect at the time the information was collected.

How To Contact Us With Questions
Your questions, comments and feedback are very important to us. For privacy-related questions, contact us via email at: privacy@throttleweb.com.