Privacy Policy

Last Revised: October 23, 2026

The Shipyard, LLC (also, the “Company,” “we,” “us” or “our”) is an advertising, creative, media services, and data analytics consultancy. The Company respects the right to privacy of individuals with whom we interact or whose information we receive (also, “consumer(s),” “you” or “your”). This Privacy Policy summarizes what personal information (as defined below) we may collect as described herein, how we may use this information and to whom we may disclose it, as well as other important topics relating to privacy and data protection.

It is the Company’s policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners, and others who share their personal information with us.

This Privacy Policy applies to personal information collected through the Company’s website, located at www.theshipyard.com (the “Website”), as well as to personal information we may collect: (i) through providing our services; (ii) when you interact with us by means other than the Website (for example, in person or by telephone); and (iii) from our customers, distributors, suppliers, vendors, and other business partners (collectively “Business Partners”).

Our collection and use of personal information we receive from and about job applicants, employees, contractors employed in our workforce and others similarly situated (collectively, “Employees”) is governed by our Employee Privacy Policy rather than by this Privacy Policy.

The Company’s Collection, Use and Disclosure of Personal Information

In keeping with applicable law, when the Company collects personal information, we will endeavor to:

• Provide notice to you about our data practices through this Privacy Policy;
• Collect and retain your personal information for a finite duration described herein (see below) and only for specified and legitimate purposes and to the extent relevant, adequate, and not excessive for the purposes for which it is collected;
• Process your personal information in a manner consistent with the purposes for which it was collected or to which you have consented;
• Make sure that your personal information is reliable for its intended use, accurate, complete and, where necessary, kept up-to-date;
• Not use or share your personal information for direct marketing or targeted advertising purposes without giving you an opportunity to opt-out; and
• Take reasonable measures, by contract or otherwise, to provide protection for personal information that is disclosed to third parties or transferred to another country, including transfers within the Company.

INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information” or “personal data”). For purposes of this Privacy Policy, personal information does not include:

• Publicly available information from government records;
• Anonymized, deidentified, or aggregated consumer information;
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996, as amended (HIPAA), the California Confidentiality of Medical Information Act, as amended (CMIA), or clinical trial data; and
• Information covered by certain other sector-specific privacy laws, like the Fair Credit Reporting Act, the Farm Credit Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We collect or receive personal information from or about you in several ways:

• Information You Provide
  

  The Company collects personal information you provide us, which may include: (i) contact information, such as your name, company name, job title, address, e-mail address, and phone number; (ii) username and password for any accounts you may establish; (iii) additional information about how you use our services; (iv) comments, questions, requests, and orders you may make; (v) financial information needed to process payments if you make purchases, such as credit card or account information or tax identification number; and (vi) information about your preferences, such as your preferred methods of communication and the types of services in which you are interested.

• Information Automatically Gathered from Your Device

  • Device and browser information:
    

    The Company may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. The Company collects this information automatically from your device and web browser through cookies and similar technologies.

  • Information about how you interact with us:
    

    The Company may collect technical data about your usage of the Website and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, Company promotional emails opened, and dates and times of interactions. The Company collects this information using cookies and similar technologies.

  • Location information:
    

    The Company may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code.

• Cookies and Similar Technologies

  • Cookies:
    

    A “cookie” is a file of information placed on your device when you visit a website. Cookies and similar technologies can enhance your user experience by saving your preferences, personalizing your online experience, and sometimes providing you with advertising which is tailored to your interests. The Website uses “session cookies.” A session cookie does not identify you personally and expires after you close your browser. The Website also uses “persistent cookies.” These cookies do not expire when you close your browser. Persistent cookies stay on your computer until you delete them or they expire. By assigning your computer a unique identifier, we are able to create a database of your previous choices and preferences which can be provided by us automatically, saving you time and effort on future visits. You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our Website if cookies are disabled. You may wish to visit www.allaboutcookies.org which contains comprehensive information explaining how to modify the cookie settings on a wide variety of browsers. You will also find details explaining how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile phone or tablet, you will need to refer to your device manual. Please note that you will not be able to opt out of receiving certain cookies that are strictly necessary for the delivery of a service requested by you. Targeting advertising can occur via third-party cookies, and we honor recognized opt-out preference signals where required, which will reduce or stop such tracking/ads.

  • Analytics:
    

    The Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, but please note that if you do this you may not be able to use the full functionality of this Website. By using this Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. To opt out of being tracked by Google Analytics across all websites, visit https://tools.google.com/dlpage/gaoptout.

• Information from Business Partners and other Third Parties
  

  The Company collects or receives personal information through our Business Partners. This information may include contact information, such as name, company name, job title, address, e-mail address, and phone number.  We may also receive information regarding personal preferences and behavior data from Business Partners, such as responses to surveys or quizzes conducted on their websites.The Company may also obtain personal information from other third-party sources, including publicly and commercially available sources. We may combine the information we receive from our Business Partners and other third-party sources with information that we collect from you or your device, as described above.  You have choices about the personal information you provide the Company. You may choose not to provide information that we request, but if you do so, we may not be able to provide you a relevant service or a particular feature of the Website.

Categories of Personal Information

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under certain state or federal laws.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, or genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES
L. Sensitive information.	Social Security Number; driver’s license number; passport number; financial account and payment card information; precise geolocation; health information; race; ethnicity; religion; union membership; private personal communications, such as chats between community members; and sex life or sexual orientation.	YES

We obtain the categories of personal information listed above (with a “yes” in the foregoing chart) from the following categories of sources:

• Directly from you. For example, from forms you complete or services you purchase.
• Indirectly from you. For example, from collecting data based on your actions on our Website.
• Through lead generation tools, such as Winmo.

Unless otherwise specified, we retain the categories of personal information listed above (with a “yes” in the foregoing chart) for as long as necessary to fulfill the purposes for which the data was collected, if and as specified, or for a period of five (5) years following the last communication or interaction with or indication of interest or response from the individual identified by such personal information, subject to legal or operational exceptions stated herein.

USE OF PERSONAL INFORMATION

We may use, share or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a service, we will use that information to process your payment and facilitate delivery.

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a service, we will use that information to process your payment and facilitate delivery.
• To provide, support, personalize, and develop our Website and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (subject to your Right to Opt-Out of Sale and/or Sharing (Targeted Advertising), where required by law).
• To help maintain the safety, security, and integrity of our Website, services, databases, and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information.
• To introduce you to additional services/offerings that are applicable based on your interests/needs.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users/consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

When you provide us with personal information, you represent and warrant (a) that (i) you are at least eighteen (18) years of age; (ii) you have the full right and authority to provide such personal information (including personal information concerning a third party); (iii) such personal information is accurate, reliable, and relevant to our relationship; and (iv) your provision and our use of such personal information, as contemplated herein, will not violate any applicable law, statute, or regulation or infringe upon a person’s data privacy rights or privileges; and (b) that you consent to our use of such personal information consistent with this Privacy Notice.

SHARING, DISCLOSING PERSONAL INFORMATION

We may share your personal information for purposes of targeted advertising, subject to your right to opt-out of such sharing (see Exercising Access, Data Portability, Correction, and Deletion Rights) or disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we routinely enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We may share your personal information with the following categories of third parties:

• Processors and other service providers
• Analytics providers
• Advertising/marketing partners
• Cloud/hosting providers.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following personal information for a business purpose:

• Category A: Identifiers.
• Category F: Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.

No Sale of Personal Information

We do not sell, and in the preceding twelve (12) months we have not sold, any personal information. We may share personal information for cross-context behavioral advertising/targeted advertising as described in this Privacy Policy. You may opt out of sharing (and any sale, where applicable) via visiting www.theshipyard.com and clicking on the link “Do Not Sell or Share My Personal Information,” by email, or by calling our toll-free number.

YOUR RIGHTS AND CHOICES

In keeping with the laws in certain jurisdictions, this Privacy Policy recognizes specific rights that consumers may exercise regarding their personal information. This section describes and explains how to exercise those rights.

Access to Specific Information and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Correction, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we shared that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).

If we disclosed your personal information for a business purpose, lists disclosing

• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Correction and Deletion Request Rights

You have the right to request that we correct inaccuracies in any of your personal information that we possess or delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Correction and Deletion Rights), we will correct or delete (and direct our service providers to correct or delete) your personal information in or from our records, unless an exception applies.

We will use commercially reasonable efforts to correct inaccurate personal information about you which is in our possession and identified by you or, alternatively, delete the purportedly inaccurate personal information if the deletion does not negatively impact you, in each case unless an exception applies, and instruct our service providers and contractors to make the necessary corrections in their respective systems.

We may deny your correction or deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with certain federal or state laws (like, e.g., the California Electronic Communications Privacy Act, Cal. Penal Code § 1546 et. seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

You may appeal our denial of your correction or deletion request by submitting your appeal to: privacyquestions@theshipyard.com.

Right to Opt-Out of Sale and/or Sharing (Targeted Advertising)

You have the right to direct us to not sell your personal information and not to share your personal information for cross-context behavioral advertising/targeted advertising (see Exercising Access, Data Portability, Correction, and Deletion Rights).

Exercising Access, Data Portability, Correction, and Deletion Rights

To exercise the access, data portability, correction, and deletion, and opt-out rights described above, please submit a verifiable consumer request to us by either:

Calling us at 800-211-3377
Emailing us at privacyquestions@theshipyard.com
Visiting www.theshipyard.com and clicking the link “Do not Sell or Share my Personal Information”

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

Such a verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
• Relationship to The Shipyard
• First and last name
• Phone number
• Email address
• Mailing address, including street, suite/apt number, city, state, and zip code
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We will not discriminate against you for exercising any of your privacy rights under this Privacy Policy except as permitted by law.

Response Timing and Formats

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at our option.

As noted above, you may appeal our denial of your correction or deletion request by submitting your appeal to: privacyquestions@theshipyard.com.

Links to Third-Party Internet Sites and Plugins

The Website may contain links to websites or mobile apps that are not operated by the Company and plugins from social media platforms and other third parties. Some examples of links to a third-party website include those websites operated by our Business Partners, suppliers, advertisers, sponsors, licensors, and other third parties. Examples of social media plugins are the Facebook “Like” button and the option to “Share” the Website through your email, Facebook, Twitter, Instagram, and LinkedIn. We provide these links and plugins as a service and do not imply any endorsement of the activities or content of the related websites, apps, or social media platforms, nor any association with their operators. To learn about the information collected by these third-party websites, apps, and plugins, please visit their privacy policies. We encourage you to review the privacy policies for the websites, apps, and social media platforms you visit before using them or providing personal information.

Children

The Website is not intended for people under 16 years of age. The Company will not knowingly solicit or collect personal information from or about people under age 16, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law. We do not knowingly sell or share the personal information of consumers under 16 years of age.

Changes To This Privacy Policy

Changes to this Privacy Policy will be posted on this Website, along with the revision effective date thereof and information on any material changes. The Company reserves the right to update or modify this Privacy Policy at any time and without prior notice. Any modifications will apply to the personal information we collect after the posting.

State Data Privacy Laws in U.S.

Depending on your state of residency, you may have certain rights related to your personal data, including:

• Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information, and it will be included in the response to your access request.
• You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information’s nature and processing purpose.
• You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law.
• Opt Out of Using Personal Data for Sales, Targeted Advertising, and Profiling for Certain Legal or Similarly Significant Decisions. You may request that we do not use your personal data for these purposes. Some states may also grant you the ability to learn more about or challenge those automated decisions.

Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, please call us at 800-211-3377, email us at privacyquestions@theshipyard.com, or visit www.theshipyard.com. To appeal a decision regarding a consumer rights request, please email privacyquestions@theshipyard.com.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

Nevada Residents

Nevada provides its residents with a limited right to opt out of certain personal data sales. Residents who wish to exercise their sale opt-out rights may submit a request to this designated address: Privacy Questions, The Shipyard, LLC, 4030 Easton Station, Suite 300, Columbus, OH 43219, 800-211-3377 or privacyquestions@theshipyard.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

California Residents

If you are a California resident, additional information applies to you. This section provides supplemental information required under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

Personal Information We Collect

In addition to the categories of personal information described above, California law requires us to disclose the categories of personal information we have collected using specific statutory categories. The chart entitled “Categories of Personal Information” in the “INFORMATION WE COLLECT” section above identifies these categories.

Categories of Sources

We obtain personal information from the sources described in the “INFORMATION WE COLLECT” section above, including: – Directly from you – Indirectly from you through your interactions with our services – From our Business Partners and service providers – From lead generation tools – From publicly available sources

Business or Commercial Purposes

We collect, use, and disclose personal information for the business and commercial purposes described in the “USE OF PERSONAL INFORMATION” section above.

Categories of Third Parties

We may disclose personal information to the categories of third parties identified in the “SHARING, DISCLOSING PERSONAL INFORMATION” section above.

Sale and Sharing of Personal Information

As stated above, we do not sell personal information. We may share personal information for cross-context behavioral advertising purposes. You have the right to opt out of such sharing.

Retention

We retain personal information as described in the “INFORMATION WE COLLECT” section above.

Sensitive Personal Information

Some of the personal information we collect may be considered “sensitive personal information” under California law, including: – Social Security numbers, driver’s license numbers, and passport numbers – Account login credentials combined with passwords – Precise geolocation data – Financial account information

We use and disclose sensitive personal information only for purposes permitted under California law, including: – Performing services you reasonably expect – Detecting and preventing security incidents – Resisting malicious, fraudulent, or illegal actions – Ensuring physical safety – Verifying or maintaining the quality of our services – Processing transactions and providing customer service

You have the right to limit our use and disclosure of your sensitive personal information to these permitted purposes.

Your California Privacy Rights

In addition to the rights described in the “YOUR RIGHTS AND CHOICES” section above, California residents have specific rights under the CCPA/CPRA:

1. Right to Know: You may request that we disclose:
   • The categories and specific pieces of personal information we have collected about you
   • The categories of sources from which we collected your personal information
   • Our business or commercial purpose for collecting or selling personal information
   • The categories of third parties with whom we share personal information
   • The categories of personal information we have disclosed for a business purpose
2. Right to Delete: You may request deletion of personal information we have collected from you, subject to certain exceptions.
3. Right to Correct: You may request correction of inaccurate personal information we maintain about you.
4. Right to Opt-Out: You may opt out of the sale or sharing of your personal information.
5. Right to Limit: You may limit our use and disclosure of your sensitive personal information.
6. Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA rights.

Exercising Your California Rights

To exercise your rights to know, delete, or correct, please: – Call us at 800-211-3377 – Email us at privacyquestions@theshipyard.com – Visit www.theshipyard.com and click on the link “Do Not Sell or Share my Personal Information”

To exercise your right to opt out of sharing for targeted advertising, please – Use the “Do Not Sell or Share My Personal Information” link on our Website www.theshipyard.com – Call us at 800-211-3377 – Email us at privacyquestions@theshipyard.com

Verification Process

We will verify your identity before processing your request. We may request information such as your name, email address, phone number, and relationship to The Shipyard. For requests involving sensitive information, we may require additional verification.

You may designate an authorized agent to make requests on your behalf. The authorized agent must provide proof of authorization.

Response Timing

We will acknowledge receipt of your request within 10 business days and respond substantively within 45 days. If we need additional time (up to 90 days total), we will notify you of the reason and extension period.

California “Shine the Light” Law

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of your personal information to third parties for their direct marketing purposes within the past year. You may make such a request by contacting:

Privacy Questions

The Shipyard, LLC
4030 Easton Station
Suite 300
Columbus, OH 43219
1-800-211-3377
privacyquestions@theshipyard.com

Residents of the European Economic Area

The Company’s lawful basis for processing your personal data:

The lawful basis for the Company’s processing of your personal data will depend on the purposes of the processing. For most personal data processing activities covered by this Privacy Policy, the lawful basis is that the processing is necessary for the Company’s legitimate business interests. Where we process personal data in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. When we are required to share personal data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location data from your mobile device.

Processing on the basis of legitimate business interests:

When we process personal information on the basis that the processing is necessary for our legitimate business interests, such interests include: (i) providing, improving, and promoting the Website and services; (ii) communicating with current and potential customers, other Business Partners, and their individual points of contact; (iii) managing our relationships with our customers and other Business Partners, and their individual points of contact; (iv) other business development purposes; (v) sharing information within the Company, as well as with service providers and other third parties; and (vi) maintaining the safety and security of our products, services, and employees, including fraud protection.

Processing on the basis of performance of a contract:

Examples of situations in which we process personal information as necessary for performance of a contract include e-commerce transactions in which you purchase a service from the Company, on your own behalf, through the Website.

Processing on the basis of consent:

Examples of processing activities for which the Company uses consent as its legal basis include: (i) collecting and processing precise location information from your mobile device; (ii) sending promotional emails when consent is required under applicable law; and (iii) processing personal data on the Website through cookies and similar technologies when consent is required by applicable law.

Processing because the Company is under a legal obligation to do so:

Examples of situations in which the Company processes personal data to comply with its legal obligations include: (i) payment of taxes and other government levies; (ii) providing your personal data to law enforcement agencies and other governmental bodies when required by applicable laws; (iii) retaining business records required to be retained by applicable laws; and (iv) complying with court orders or other legal process.

Additional information about the retention of your personal data:

To determine the period for which your personal data will be retained in accordance with this Privacy Policy, the Company considers criteria such as: (i) any applicable legal requirements to retain data for a certain period of time; (ii) any retention obligations related to actual or potential litigation or government investigations; (iii) any retention requirements in relevant agreements with our Business Partners; (iv) the date of your last interaction with the Company; (v) the length of time between your interactions with the Company; (vi) the sensitivity of the data; and (vii) the purposes for which the data was collected.

Your individual rights:

In accordance with the applicable laws in the European Union, you have the following rights with respect to your personal data, which apply differently in different circumstances: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability, and right to object to processing. Most of these rights are not absolute. Below we describe these rights in more detail and provide information on how you can exercise them. If you make a request to exercise your rights, we will respond within one month, but have the right to extend this period by two additional months, where necessary. If we extend the response period, we will let you know within one month from your request.

You can exercise your rights by contacting:

Privacy Questions

The Shipyard, LLC
4030 Easton Station
Suite 300
Columbus, OH 43219
1-800-211-3377
privacyquestions@theshipyard.com

Right of access:

You have the right to ask the Company to confirm whether we process your personal data. If we do, you have the right to request access to your personal data that we process and the following information: (i) the purposes of the processing; (ii) the categories of personal data we process; (iii) the recipients or categories of recipients of your personal data; (iv) the envisaged retention period of the data where possible, or the criteria we use to determine the retention period; (v) your right to request rectification or erasure of your personal data, or restriction of the processing of such data; (vi) your right to file a complaint with a supervisory authority; (vii) if we have not collected the data from you, any information we have available about the source of the data; and (viii) whether we use your personal data to make any automated decisions that have legal or other similar significant effects on you.

Right to rectification:

You have the right to have the Company correct your personal data if it is inaccurate. Taking into account the purposes of the processing, you may also have the right to have incomplete personal data about you completed, including by providing a supplementary statement to the Company.

Right to object to processing for the Company’s legitimate business interests:

You have the right to object to the Company processing your personal data when that data is processed on the basis of the Company’s legitimate business interests. The Company will honor your objection and stop processing the relevant personal data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, and freedoms; or (ii) we need to continue processing your personal data to establish, exercise, or defend a legal claim.

Right to object to processing for direct marketing:

If the Company processes your personal data for direct marketing purposes, you have the right to object to this processing. If you exercise this right, the Company will stop processing your personal data for direct marketing purposes.

Right to restrict processing:

You have the right to request that the Company restrict the processing of your personal data in the following circumstances: (i) for the period of time the Company needs to verify the accuracy of your personal data when you contest its accuracy; (ii) when the processing of your personal data is unlawful and you oppose the erasure of the data, and instead request that the Company restrict the use of the data; (iii) when the Company no longer needs your personal data for the purposes of processing, but you need the data to establish, exercise, or defend a legal claim; or (iv) for the period of time the Company needs to verify if it has compelling legitimate grounds for processing that override your interests, rights, and freedoms when you object to the processing of your personal data for the Company’s legitimate business interests. If following your request, the Company restricts the processing of your personal data, we will store your data and otherwise process it only with: (i) your consent; (ii) to establish, exercise, or defend a legal claim; (iii) to protect the rights of another natural or legal person; or (iv) for reasons of important public interest of the European Union or a Member State. The Company will also inform you before lifting the restriction of processing.

Right to erasure:

The right to erasure is also called the “right to be forgotten.” You may ask the Company to delete your personal data. This right is not absolute. The Company is required to delete your personal data upon your request only in the following circumstances: (i) when your personal data is no longer necessary for the purposes for which we collected or processed data; (ii) if the Company processes your personal data on the basis of consent, you withdraw your consent, and no other legal ground exists for us to continue processing your personal data; (iii) if the Company processes your personal data for its legitimate business interests, you object to the processing, and there are no overriding legitimate grounds for us to continue processing your personal data; (iv) if the Company has processed your personal data unlawfully; or (v) the personal data must be erased to comply with a legal obligation under European Union or Member State law to which the Company is subject. The Company is not required to erase your personal data to the extent that the Company needs to process data to: (i) exercise its right of freedom of expression and information; (ii) comply with a legal obligation under European Union or Member State law to which the Company is subject; or (iii) to establish, exercise, or defend a legal claim.

Right to data portability:

You have the right to receive personal data you provided to the Company when: (i) the processing of the data is based on your consent or is necessary for the performance of a contract between you and the Company; (ii) the Company’s processing of your personal data is carried out by automated means; and (iii) complying with your request will not adversely affect the rights and freedoms of others.

If you have the right to receive such personal data and request that we provide it, the Company will provide it to you in a structured, commonly used, and machine-readable format.

Right to lodge a complaint with a supervisory authority:

The Company will use its best efforts to address and settle any requests or complaints brought to its attention. In addition, you have the right to approach the competent data protection authority with requests or complaints. This can be the supervisory authority in the country or federal state where you live.

Questions About This Privacy Policy

If you have any questions about this Privacy Policy or our use of your personal information, please contact:

Privacy Questions

The Shipyard, LLC
4030 Easton Station
Suite 300
Columbus, OH 43219
1-800-211-3377
privacyquestions@theshipyard.com