PRIVACY POLICY

Policy Effective: January 20, 2026

We understand that our customers are concerned about privacy and have created this Privacy Policy to help you understand how Do it Best® Group (consisting of Do it Best Corp. and its Affiliates, including Do it Best Commerce Company, LLC and affiliates associated with True Value® such as such as TV Holdco LLC, TV Hardware Distribution LLC) (collectively, “Do it Best Group,” “we,” or “us”) collect, use and protect the personal information of (a) users who access and use our websites, mobile applications or other online services (collectively, “Sites”), including offerings made available through our Sites and under the Best Rewards, True Value Rewards, and other Programs (collectively, the “Services”); (b) customers who purchase products (collectively, “Products”) from us via our Services or from the independently owned and operated stores in our and our Affiliates’ cooperatives as well as other retailers and local business owners approved by us (collectively, “Stores”); and (c) any other individuals from whom we collect personal information during the course of our business activities. In this Privacy Policy the term “including” means “including but not limited to” and is exemplary rather than exclusive. “Affiliates” means any entity that controls, is controlled by, or is under common control with Do it Best Corp., and “control” for purposes of this definition means possession, directly or indirectly, of the power to direct the management and policies of an entity or person whether through the ownership of voting securities or other ownership interest, by contract or otherwise. This Privacy Policy does not apply to Affiliates or Stores that have a separately posted Privacy Policy or to Do it Best Group employees.

Privacy Policy describes the personal information that Do it Best Group collects, how we use your personal information, with whom we may share such data, and how you can contact us, access your personal information, and exercise your rights regarding use of your personal information. As used in this Privacy Policy, “personal information” means data that identifies, relates to, describes, or is linked to a particular identified or identifiable natural person or is otherwise considered personal information under applicable privacy This and/or data protection laws or regulations. By using or accessing our Sites, Services or otherwise providing personal information to us, you signify your acknowledgment and assent to the “Privacy Policy” set forth below and consent to collection and use of personal information as described in this Privacy Policy. If you do not agree to all parts of this policy, please do not use our Site or Services or otherwise provide personal information to us. Do it Best Group can revise this policy at any time by updating this posting or otherwise providing notice as set forth in this Privacy Policy, and your use or provision of personal information after such change signifies your acceptance of the changed terms. Please check this Privacy Policy periodically for changes.

1. COLLECTION OF PERSONAL INFORMATION

Sources: We may collect personal information from or about you in a variety of ways, including directly from you and your devices, from Third-Party Services (as explained below), from our Affiliates and related companies, from Stores, from public sources, from friends (if a friend purchases something for you), and from marketing partners, data brokers and other third-party sources. Collection methods include: (a) from you directly such as from forms on our Sites or from contacts with our call centers; (b) from you when you visit a Store or attend an event sponsored by us or a Store; (c) in connection with Product orders (including contact information, shipping information, e-mail address and payment card information); (d) from surveys; (e) when you submit an inquiry to us or request to receive additional information regarding Products and Services; (f) from contracts, service applications, subscription agreements, or other agreements or forms you fill out; (g) from your activities in connection with offerings, promotions and promotional programs (collectively, “Programs”), including contests and sweepstakes, the Best Rewards^SM loyalty Program (“Best Rewards”), and the True Value Rewards® loyalty Program (“True Value Rewards”); (h) from individuals and/or entities whom you have authorized to act on your behalf and/or to provide information about you; (i) from publicly available sources (where permissible by applicable law); or (j) from other communications with us, including calls, emails, chats, texts and social media posts. In order to use certain Services, you may be required to set up an account with us (an “Account”). The term Account includes any account you establish for a Program. During the Account registration process, we may ask you for certain personal information to establish and use your Account. We may also collect information about you in connection with your transactions or interactions with us, a Store or any of our Affiliates or Service Providers (including chat and SMS service providers). We may combine the information you submit under your Account with other information that we may receive from you, from third parties, or with other public information.

Categories: Collected personal information may include the following categories of data:

• Personal identifiers and characteristics (such as name, age, gender, birthday)
• Contact information (such as shipping address, email address, phone number)
• Financial information (such as payment details, billing address)
• Usage Information (defined in Section 2) regarding you and the device you use to access our Services
• Transaction data (such as products and services used, liked, viewed, ordered or preferred, reviews submitted, and information on interactions with our Sites, offerings and Stores)
• Demographic information (such as preferences, profession, and marital status)
• Location information (including precise location if enabled on your device)
• Inferences based on other collected information

Not all categories may be collected about every individual. You may at any time refuse to provide any personal information that we request, however this may limit your ability to access certain services, options or content.

Collected sensitive personal information consists of precise geolocation data. You may limit the collection of precise geolocation data through applicable settings on your device. We do not use, maintain or disclose sensitive personal information for purposes other than to perform services on behalf of our business such as determining your nearest store, assigning you a designated home Store, and customizing certain functions of the Services, such as product availability, pricing, and local advertising. We do not sell your sensitive personal information or share it with others in contravention of applicable law.

2. PASSIVE COLLECTION OF TRACKING AND USAGE INFORMATION

Information may be collected related to your use of the Sites and Services, including data about the devices and programs from which you access such offerings (“Usage Information”). Usage Information can include: (a) the name of the domain and host from which you access the Internet; (b) the Internet Protocol (IP) address of the device you are using; (c) the browser software and operating system you are using; (d) mobile device type, device operating system, device identifiers, and device settings, (e) country of origin and location (as obtained from your IP address and your precise location if enabled on your device or application); and (f) the address of the website from which you have arrived at our Site or Services or the website address you visit when you leave. Usage Information may also relate to your interactions with our Sites and Services, including the date and time of access, the length of time spent, the pages or products accessed or videos viewed while visiting, links clicked, favorites designated, items viewed or placed in your cart, number of visits, search history, and browsing history. We may link Usage Information to personal information. Usage Information is collected to help us manage and administer our Services and systems; to improve the content of our Services and Products; to make product recommendations and provide promotional content; to localize content (including to provide availability, correct pricing, and local ads); to monitor and tailor our marketing activities; to customize and improve user experience; to recognize returning customers; to store preferences or login credentials; to measure the effectiveness of our advertising; to fulfill purchases; and for security and fraud detection purposes. Usage Information is gathered using general detection and use of your internet protocol (IP) address, device identifiers or domain name and the following methods:

Cookies

Usage Information may be collected through the use of “cookies,” which are small text files saved by your browser or device that serve a number of purposes, such as remembering your preferences and generally improving your user experience. We (and Service Providers and Third-Party Services) may use both session cookies and persistent cookies to gather analytics about our Site and Services, including Usage Information and demographic information, in order to monitor usage and traffic, improve performance and customize users’ experience. For example, they help us to identify Account holders and loyalty Program members. Some cookies are required for technical reasons in order for our Services to operate (“strictly necessary cookies”). We may also use cookies to track and target you as a user and tailor our Services to your interests based on your previous online shopping preferences. For example, if you visit the plumbing section of our Site, the Site would “remember” the visit and let you know of specials, new products, or related plumbing projects upon a future Site visit. Cookies also allow us to hold selections in a shopping cart when a user leaves without checking out. Cookies set by us are called “first party cookies.” Cookies set by Service Providers, Third-Party Services or other third parties are called “third party cookies.” Third party cookies enable third party features or functionality like advertising and analytics as discussed in Section 8. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies, limit third party cookies, or to prompt you before accepting cookies. Please note, however, that if you don’t accept strictly necessary cookies, you may not be able to access all portions or features of our Sites or Services. Your mobile device may not give you the ability to control cookies. If you wish to block cookies on a mobile application, you may need to delete the application from your mobile device. You can set your preferences regarding the use of cookies via our Manage Preferences page (click here). Please note that if you select “Reject All”, cookies classified as “strictly necessary” will still be operational on our Sites, as they are necessary for the website to function correctly and provide you the Services. If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent our Sites from placing further cookies on your device unless and until you adjust your browser options.

Tags/Beacons

Usage Information may be collected through the use of software technology called tags or web beacons (a.k.a. pixel tags, tracking pixels or clear gifs) which are tiny graphics files that contain a unique identifier that help us, Third-Party Services, or Service Providers monitor website activity (such as when you view a web page, advertisement, or message that contains the web beacon) and better manage Services content and communications by informing us what content is effective and how it is used. Such technology may also be used for web analytics, processing, security and fraud detection purposes. These beacons (or other tracking technology) may also be included in or associated with e-mails or other communications that you receive from us (or Service Providers or Third-Party Services) in order to help us track your response and interests and to deliver you relevant content and services. For Account holders we may link Usage Information gathered by beacons or other tracking technology to personal information.

Location Data

When you use certain features of our Services, including store locator functionality, we may receive, store and process different types of information about your location, including general information (e.g., IP address, zip code) that can be used to determine your location, and if enabled on your mobile device more precise geolocation information that is provided to us by your device. You may adjust your privacy controls appropriately.

3. USE AND PROCESSING OF PERSONAL INFORMATION

We use and process your personal information for reasonable and legitimate business purposes, to perform and fulfill our contractual obligations to you, for promotional and marketing purposes, and to comply with legal obligations, including for the following purposes:

• Contacting you regarding business transactions and information related to the Products or Services you have ordered (for example, we use your order information to fulfill your order and send an order or shipping confirmation, as well as notify you of your order status);
• Providing our Products and Services to you (for example, if you provide us with personal information in order to place an order with us, we will use that information to process your payment, complete the sale and ship Product to you);
• Administering, maintaining and managing our business relationship and/or providing ongoing support to you;
• Communicating with you about our Products and Services (including as appropriate product recalls) and other offerings and promotional activities of Do it Best Group and its Stores;
• Monitoring and tracking marketing activities, generating insights and metrics, and making recommendations, performing identity resolution and retargeting, generating lookalike audiences, and showing customized or targeted ads, promotions, and content to you (including through personalized, cross-context, targeted and interest-based advertising);
• Responding to your comments, reviews, or requests for information;
• Administering Programs, including the Best Rewards Program and True Value Rewards Program (if you are a member of those programs), as more specifically described in the applicable Program Terms therefor;
• Using location information to assign you a designated home Store and to customize certain functions of the Services, such as Product availability, pricing, local advertising, and the store locator feature;
• Enforcing any contracts that we enter into with you, or defending claims arising from such contracts;
• Contacting you regarding future opportunities and changes in our activities, products and services;
• Customizing and optimizing our Services and customer experience, including by generating insights and metrics regarding our operations and strategies, assessing trends and interests, and making recommendations;
• Enhancing the security of our network and information systems;
• Developing, enhancing, and improving the Services, Products and offerings of us and Stores;
• Understanding and monitoring how people interact with our Site, Services and offerings;
• For safety and security purposes, including where necessary to protect the rights, property or safety of us or other users or customers;
• For event planning and administration;
• Complying with our obligations under applicable law, industry guidelines and internal policies;
• Where we are obligated, or permitted, to do so by applicable law, regulation or legal process, including disclosure to tax, customs or other governmental authorities; or
• As described to you when collecting your personal information.

We do not use your personal information without a lawful basis, or for purposes contrary to this Privacy Policy, without your consent. We do not use artificial intelligence for automated decision making or profiling in violation of applicable law.

4. PROMOTIONAL MESSAGES

When you purchase Products, participate in Services, request Product information or otherwise provide us with personal information, we and/or a Store (such as one with whom you have interacted or placed an order) may automatically place you on a list to receive promotional mailings and e-mails regarding special offers from Do it Best Group, such Store or their affiliates, or from other companies we think you may find interesting. If you do not wish to receive these messages from us, you can simply utilize the unsubscribe or opt-out method detailed in the message or contact Customer Care using the contact information specified below in Section 23. Even if you opt-out of receiving promotional messages you may still receive transactional emails and messages relating to orders, earned rewards, administrative matters, or your Account. Please note that even after opting-out from receiving messages from us, you may continue to receive promotional messages from a Store and you would need to separately opt-out using the methods detailed in any message from such Store.

5. MEMBERS AND MEMBER WEBSITES

Stores (even if branded in the name of Do it Best, True Value, or an Affiliate) are independently owned and operated. Do it Best Group is not legally liable for actions taken or data collected by Stores. A Store’s use of personal information you provide in connection with your activities at a Store, including purchases at a Store, will be governed by the Store’s applicable privacy policy (not this Privacy Policy) which may include use of such information for the Store’s own marketing and business purposes. Stores may provide us with certain of your personal information in connection with the Best Rewards and True Value Rewards Programs as described in Section 6.

In some cases we host or otherwise operate the ecommerce websites or online services of Stores (“Hosted Store Services”) which may permit you to purchase Products via a Store’s website. When you order Product via Hosted Store Services, we will receive the personal information you provide in connection with such order and will treat such personal information in accordance with this Privacy Policy. In such cases, the Store will also receive your personal information, and its usage of such information will be governed by the Store’s applicable privacy policy which may include use of such information for the Store’s own marketing and business purposes.

If you order a Product via our Services and choose to have the Product shipped to a Store for pick up (a “Ship-to-Store Order”), the Store will receive the personal information you provide in connection with such Ship-to-Store Order and the Store’s usage of such information will be governed by the Store’s applicable privacy policy which may include use of such information for the Store’s own marketing and business purposes.

Do it Best Group is not responsible for (and shall not be liable for) for the privacy practices or policies of Stores. By accessing and using Hosted Store Services or placing a Ship-to-Store Order you consent to the transfer to and processing and use of your personal information and related Usage Information by the applicable Store for its own purposes.

6. LOYALTY AND OTHER PROGRAMS

If you choose to participate in a Program, personal information will be collected, used, processed, disclosed, shared and sold by us as provided in this Privacy Policy, including collection of the categories of personal information identified in Section 1 which are shared with the categories of persons identified in Section 7. You may choose to participate in a Program by opening an Account, enrolling via a Site or in-store, redeeming a coupon provided in connection with a Program, or otherwise signing up as provided in applicable Program promotional materials. You may opt-out of participation by ceasing to participate in the Program (including by cancelling your Account) or by contacting us as provided in Section 23. Opting out of sharing or selling of your personal information as provided in Section 11, will also terminate your participation in Programs that involve sharing of your personal information with Stores and other third parties, including the Best Rewards and True Value Rewards loyalty programs. Some Programs may be subject to different or additional terms, rules, guidelines or policies (“Program Terms”) made available upon enrollment or via applicable Program Sites. Click here for details of applicable Program Terms for the Best Rewards and click here for the True Value Rewards Programs.

Operation of the Best Rewards and True Value Rewards loyalty programs is reliant on the exchange of personal information between us and Stores to calculate and redeem loyalty rewards. If you participate in a loyalty Program we will receive personal information in connection with any purchases you make using your loyalty Program rewards number (a “Rewards Number”), including purchases at a Store using your Rewards Number. Such information will include details of the purchase and point-of-sale information, including product, price, quantity, and discounts. We will treat your personal information collected by us in connection with the loyalty program in accordance with this Privacy Policy. We may exchange personal information relating to your participation in a loyalty program with Stores, including your personal identifiers and characteristics, contact and demographic information, transactional information, and information regarding your use of Sites, Services, and Hosted Store Services, and the products you purchase. A Store’s usage of such information will be governed by the Store’s applicable privacy policy (not this Privacy Policy) which may include use of such information for the Store’s own marketing and business purposes. We do not provide your information to data brokers. Under Best Rewards and True Value Rewards you will receive reward coupons redeemable against purchases of future products based on your transactions and past products purchased (for example, a $5.00 coupon when you have spent $250 in purchases).

Do it Best Group is not responsible for (and shall not be liable for) for the privacy practices or policies of Stores. By enrolling in Best Rewards or True Value Rewards and/or using your Rewards Number (a) you acknowledge and agree that your personal information (including Usage Information) will be shared with Stores as provided in this Privacy Policy and may be used by Stores in accordance with their own privacy policies, including for their own marketing and business purposes, and (b) you consent to the transfer to and processing and use of your personal information and Usage Information by such Stores. If you do not consent and agree to such use, sharing and processing, you must withdraw from the Best Rewards (click here) and True Value Rewards Programs (click here) and may not participate in such Programs or receive program rewards or benefits.

7. SHARING OF PERSONAL INFORMATION

In connection with the purposes specified in this Privacy Policy, we may share your personal information with third parties in the following circumstances:

• We may share your personal information among our corporate Affiliates;
• We may share your personal information with Stores, including in connection with placing a Ship-to-Store Order or an order via Hosted Store Services as more fully described in Section 5;
• If you are a member of a loyalty or other Program, we may share your personal information with Stores as more fully described in Section 6;
• We may share your personal information with a Store, manufacturer, or delivery service (such as UPS, FedEx, etc.) in order to facilitate shipping, delivery, repair, return, or other services related to our Products or Services, to identify or resolve technical problems or customer service issues, to enable participation in Programs, and to conduct marketing activities.
• We may share your personal information with third party companies that perform services on our behalf, such as delivery and logistics companies, marketing companies, Payment Processors, chat service providers, and website hosting, AI technology, and other IT infrastructure providers, (collectively, “Service Providers”), including providers assisting us for security, credit or fraud prevention purposes, and we may also authorize Service Providers to collect personal information on our behalf.
• We may share your personal information with Third-Party Services as provided in Section 8, including in connection with validating, improving or enhancing collected data.
• We may disclose your personal information to third parties whom you have authorized in connection with Products and Services we provide to you.
• We may disclose your personal information as required (or requested by law enforcement) and permitted by law or regulation, including in response to a subpoena or to respond to an emergency situation.
• We reserve the right to disclose personal information in special cases when we have reason to believe that disclosing this information is necessary to protect our legal rights, including to identify, contact, or bring legal action against someone who may be causing injury or interference with (either intentionally or unintentionally) our rights or property or anyone else that could be affected by such activities.
• In the event Do it Best Group or any of its Affiliates or their assets are sold, merged or otherwise involved in a corporate transaction, your personal information will likely be transferred as part of that transaction. We reserve to right to transfer your personal information without your consent in such a situation; provided that we will make reasonable efforts to see that your privacy preferences are honored by the transferee.

Outside of the situations above, we do not share or sell your personal information with third parties unless you have specifically requested that information be released to them or have otherwise consented to such sharing (such as in the case of sharing with Stores in connection with Hosted Store Services, Ship-to-Store Orders, and loyalty Program participation).

8. INTERACTION WITH THIRD-PARTY PLATFORMS

Certain features or aspects of our Site or services may be facilitated or provided by third party providers (“Third Party-Services”), including features that collect Usage Information, generate audience or performance metrics, insights, or recommendations concerning our Site or Services, deliver or target advertising, or provide social media functionality.

Third Party Analytics

Our Websites or Services may rely on one or more third-party analytics services (“Analytics Services”) to collect Usage Information to evaluate, analyze and provide information and performance metrics regarding the use of the Websites or Services by you and by our customers in general. Analytics Services may use cookies, web tags/beacons or other collection technologies to collect and analyze such Usage Information. The Usage Information collected using Analytics Services, which may be shared with such services, doesn't include names or contact information, but may include IP addresses, and activity on the Services.

Targeted Advertising

We may interact with third-party online advertising networks, social media companies and other third-party services (“AdTech Services”) to evaluate and analyze information about your use of our Site and Services and other third-party websites over time so that they may display ads on our Sites or Services, on other devices you may use, and on third party websites, apps or services, including on social media platforms. These AdTech Services may track your online activities over time and across our Sites and Services and other websites by collecting Usage Information through automated means, including through the use of cookies, web server logs, beacons/tags and other methods. The information AdTech Services collect includes information about your visits to other websites that participate in the AdTech Services (either as an advertiser or as a site on which ads appear), such as the pages or advertisements you have viewed, and the actions you take. We may receive Usage Information about you from these AdTech Services and may associate it with personal information. Usage Information collected through our Sites and Services may be used by us and AdTech Services to provide advertising about products and services tailored to your individual interests through demographic, behavioral and contextual means (sometimes called interest-based advertising, targeted advertising, cross-context behavioral, or online behavioral advertising). We may provide an AdTech Service with customer lists to deliver ads to such customers and similar users (e.g., lookalikes) via such AdTech Service.

Conversion Tracking

We may use conversion tracking or other search engine or social media features that permit us to measure the effectiveness of search results or links and track resulting interaction with our Site or Services. These features use cookies, tags/beacons or other methods to collect Usage Information such as time of day, browser type, browser language, and IP address in connection with search queries or targeted links.

Social Media Functionality

Our Sites and Services may enable you to connect to other external services and social media features such as the Facebook “like” button, widgets such as the “share this” button, and other social media functionality. These third-party sites and features may collect your personal information and track your use of our Sites and other websites by collecting Usage Information through automated means, including through the use of cookies, web server logs, beacons/tags and other methods.

Your interaction with an AdTech Service or other Third-Party Service may permit the Third-Party Service provider to collect your personal information or Usage Information or to track user activity. We are not responsible for the data collection or privacy polices of any Third-Party Service, including their use of cookies or other tracking devices. By accessing and using the Sites or Services, you consent to the processing of Usage Information and data concerning you by Third-Party Services.

You can obtain information about the information collection practices of Third Party Services and opt-out of receiving interest-based advertising from participating members of the Network Advertising Initiative (NAI) at www.networkadvertising.org/choices/ and the Digital Advertising Alliance (DAA) at www.aboutads.info/choices/. You may also be able to opt out of or customize your participation in third party ad networks by visiting www.youronlinechoices.com/ or by clicking the “Ad Choices” icon that appears in an ad you are served. Please note that some Third Party Services may not participate in these opt-out mechanisms.

You may request to opt-out of the sale or sharing of your personal information by us as provided in Section 11, however some Third-Party Services may be able to continue collecting information about your online activities over time and across different websites and continue to use your personal information (such as to serve ads or promotional messages). You may be able to opt out of or customize such use by contacting such Third-Party Services directly. You can obtain information about the information collection practices of, and opt-out of receiving interest-based advertising from, participating members of the Network Advertising Initiative (NAI) at www.networkadvertising.org/choices/ and the Digital Advertising Alliance (DAA) at www.aboutads.info/choices/. You may also be able to opt out of or customize your participation in third party ad networks by visiting http://www.aboutads.info/choices/, www.youronlinechoices.com/, www.iabprivacy.com/optout.html/, or by clicking the “Ad Choices” icon that appears in an ad you are served. Please note that some Third-Party Services may not participate in these opt-out mechanisms.

Note that because most opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use. Your mobile device settings may also provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes. Even after using opt-out mechanisms, you may receive interest-based advertising from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

You can set your preferences regarding the use of cookies by AdTech Services and other Third-Party Services on our Sites and Services via our Manage Preferences page. For detailed information about the use of cookies please see Section 2. Cookies are specific to each device or browser, and you will need to separately set cookies for every browser and device that you use (or if you later delete cookies). You can also change your browser or device settings to stop automatically accepting cookies, limit third party cookies, prompt you before accepting cookies, or to delete cookies.

9. USE OF NON-PERSONALLY IDENTIFYING INFORMATION

We may anonymize, pseudonymize, aggregate or de-personalize personal information and/or Usage Information to create non-personally identifiable information (“Anonymized Data”). We reserve the right to freely disclose and use Anonymized Data and other non-personally-identifying information for industry analysis, statistical purposes, demographic profiling, marketing and advertising, and other business purposes. We may share Anonymized Data with Stores, Service Providers, Third-Party Services, vendors, advertisers, business partners, sponsors and other third parties.

10. PAYMENT PROCESSING

Payment card information (such as payment card name, card number, CVV and expiration date) is collected at the time of a transaction. This information is required so that payment can be authorized by a third-party payment processor (the “Payment Processor”) that we have retained to process payments made via the Services. All payment card information is provided directly to the Payment Processor and not to Do it Best Group (i.e., we do not receive or store your credit card information in connection with payments authorized through the Services). All Internet transactions with the Payment Processor are performed on a server that uses industry standard encryption technology to protect your payment card information from being obtained by unauthorized third parties. Your payment, and use of your payment and transaction information, will be subject to the privacy policies of the Payment Processor and your payment card issuer. We are not responsible for any errors by the Payment Processor or for any security breaches suffered by such entity. In connection with your payments, we may obtain certain payment transaction details from the Payment Processor, which we will use solely in accordance with this Privacy Policy.

11. PRIVACY RIGHTS AND CHOICES

In accordance with applicable state laws, consumers have the following rights with respect to their personal information:

Right to Access: You may request information about the categories and items of data we have collected about you and obtain a copy of that data. For data copy requests, we will select a format to provide your personal information that is readily useable and should allow you to exchange the information with other persons. Residents of Oregon and Minnesota also have the right to request a list of the specific third parties to whom we have disclosed personal information.

Right to Delete: You may request that we delete personal data that we have collected from you and retained, subject to certain exceptions. Please note that deletion of personal information will result in deletion of your Account on our Sites (including doitbest.com and truevalue.com), termination of your participation in Best Rewards and True Value Rewards, and loss of any loyalty points and unused rewards.

Right to Correct: You may request that we correct inaccurate personal information that we maintain about you, subject to certain exceptions.

You may review, update, correct or delete certain personal information associated with your Account by logging into your online Account. If you wish to access, update correct or delete other personal information, you can contact Customer Care using the contact information specified below in Section 23. We will comply with applicable law in responding to such requests. You do not need to have an Account to make a privacy rights request. Upon receipt of your request, we will provide directions on any identity verification requirements which may include submission of pieces of personal information that we can match to our records. Subject to applicable law, we will endeavor to respond to a verifiable consumer request within 45 days of receipt, but may request additional time if required to process your request and permitted by law. If we deny your request, we will inform you of the reason for its denial, and you may appeal the decision by contacting us using the methods described in this section. We will inform you of any action taken or not taken in response to your appeal within a reasonable time (usually 60 days or any shorter period required by applicable law) after the date of receipt of the appeal. We will provide a written explanation of the reason(s) for the decision and any additional information or resources required by applicable law.

Right to Opt-Out: Some jurisdictions may grant the right to limit the use of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. You can submit a request to opt-out by:

• Visiting our Privacy Choices page (click here) and selecting “Opt-out of the sale and sharing of my personal information", or
• Sending us an email at privacypolicy@doitbest.com.

Please note that operation of the Best Rewards and True Value Rewards loyalty Programs is reliant on the exchange of personal information between us and our Stores to calculate loyalty rewards, and if you opt-out of the sale and/or sharing of your personal information this will result in termination of your participation in those loyalty Programs and the loss of any loyalty points or unused rewards. To the extent permitted under applicable law we will endeavor to obtain your confirmation that this is your intent at the time you exercise your right to opt-out, but we will have no liability for any unintended termination of your Best Rewards or True Value Rewards Account.

Exercising your right to opt-out will affect cookies on the specific device and browser you are using, but if you access our Sites or Services anonymously or via another browser or device or have deleted cookies and we cannot determine your identity, then you will need to make a separate cookie opt-out for each browser or device. As noted above in Section 8, even after opting-out, some Third-Party Services (such as Analytics Services, AdTech Services, and social media platforms) may be able to collect information about your online activities over time and across different websites when you use our Sites or Services. These entities may use this information to show you tailored ads and content, including ads from us and Stores. You may be able to opt out of or customize such tracking as further detailed above in Section 8.

12. CALIFORNIA PRIVACY RIGHTS – CCPA NOTICE

If you are a resident in the State of California, USA, the California Consumer Privacy Protection Act (as amended by the California Privacy Rights Act) and corresponding regulations (“CCPA”) and other California statutes may apply to the personal information that you provide to us through our Sites or Services or otherwise through your interaction with us. California residents can find additional information and disclosures required under California law in our California Privacy Statement (click here) which constitutes a Notice at Collection under the CCPA.

13. DO NOT TRACK AND PROCESSING OF PRIVACY OPT-OUT PREFERENCE SIGNAL

Certain browsers and other technologies send opt-out preference signals to the websites you visit notifying the website of your desire to stop the sale or sharing of your personal information. For more information, please see http://www.globalprivacycontrols.org. Our Sites will interpret any recognized signal as a request to opt-out of sale and sharing for the relevant browser and device. At this time, an opt-out in response to the signal only applies to the browser and device you are using and only includes the online sale and sharing of your personal information during the current session. Alternatively, you can choose to provide the information requested via our Privacy Choices page (click here) and selecting “Opt-out of the sale and sharing of my personal information" which may enable us to process your opt-out request more broadly than for a specific device or browser, including cases where you are logged into your Account. Except as specified in this section, we do not employ a process for responding to “Do Not Track” (DNT) signals. As noted above in Section 8, even after opting-out some Third-Party Services (such as Analytics Services, AdTech Services, and social media platforms) may be able to collect information about your online activities over time and across different websites when you use our Sites or Services. These entities may use this information to show you tailored ads and content, including ads from us and Stores. You may be able to opt out of or customize such tracking as further detailed in Section 8.

14. SECURITY

We use commercially reasonable security measures consistent with industry practice to protect the loss, misuse and alteration of the personal information in our possession or under our control. While we use reasonable efforts to safeguard the confidentiality of your information, we cannot guarantee that data will always remain secure due to transmission errors, outside events, third-party hacking or other causes. We will comply with all applicable privacy laws and make any legally required disclosures regarding breaches of the security, confidentiality, or integrity of personal information consistent with our ability to determine the scope of a breach and our obligations to law enforcement.

15. TRANSFER OF PERSONAL INFORMATION

Do it Best Group is based in the United States of America. All personal information that you provide to us in connection the Sites and Services will be processed and maintained by us on servers in the United States, and it may also be transferred by us to Service Providers and Third-Party Services as provided herein who are located within the United States or elsewhere. By accessing and using the Sites or Services, you consent to transfer of your personal information as described herein.

16. DISCLAIMER REGARDING VIDEO CONTENT

Our Sites and Services may contain pixels which provide us with analytics regarding how users interact with video content, audiovisual content, or content of a similar nature (collectively, “Video Content”). Video Content is provided for the purpose of enhancing the user experience on our Sites and Services and by continuing to use our Sites or Services and interacting with Video Content, you understand that your personal data, including your video viewing history, may be processed according to this Privacy Policy. You may also visit Privacy Preference Manager, where you can review specific cookies in use and update your settings.

17. CHANGES TO THIS POLICY

This Privacy Policy (including any linked privacy statements and disclosures) may be updated from time to time to reflect changes to our information practices. If we make any material changes we will notify you using any contact information you have provided to us, via your Account, or by means of posting a notice or an updated version of this Privacy Policy on the Sites. We encourage you to periodically review our posted Privacy Policy for the latest information on our privacy practices. Any modifications to this Privacy Policy will be effective upon notification of the new terms or posting, and your continued use of the Site or our other products and services or provision of personal information thereafter indicates acceptance of the modified Privacy Policy. If you do not agree to any part of a modified Privacy Policy, then you must terminate your Account and stop accessing our Site and Services.

Certain Sites and Services, or specific aspects of the Services, may be subject to other privacy policies as specified in the privacy notices or statements presented to you in connection with use of such Sites or Services. In the event of a conflict between such provisions and this Privacy Policy, such specific terms shall control.

18. RETENTION OF PERSONAL INFORMATION

Do it Best Group will retain collected personal information and sensitive personal information as long as necessary to fulfill the purposes for which it was collected and as described herein, and thereafter as reasonably necessary to meet accounting, reporting, audit, or legal and regulatory requirements (including record retention requirements), to defend or bring potential legal claims, or for a longer period if we have other legitimate business reasons for retaining the information. For example, we retain your transaction history so that you can review past purchases (and repeat orders if desired) and what addresses you have shipped orders to, and to improve the relevance of products and content we recommend.

19. AUTOMATED DECISION MAKING

We do not engage in profiling of consumers in furtherance of automated decisions that produce legal or similarly significant effects, as those terms are defined under the Colorado Privacy Act or the Oregon Consumer Privacy Act.

20. NOTICE REGARDING LOYALTY PROGRAMS AND FINANCIAL INCENTIVES

We provide reward price discounts, coupons, services and other benefits for members of the Best RewardsSM and True Value Rewards® loyalty programs, Account holders, members of our mailing and email lists, and participants in other promotional Programs. Because Programs involve the collection of personal information they may be considered to be “financial incentives” or “price or service differences” requiring disclosure under applicable state privacy law. Your participation in Programs is optional. If you choose to participate in a Program, the terms of any financial incentive will be available at the time you sign up for the financial incentive and/or are available in the applicable Program Terms for each loyalty Program (click here for Do it Best and click here for True Value details). Personal information will be collected, used, processed, disclosed, shared and sold by us as provided in this Privacy Policy, including collection of the categories of information specified in Section 1 and use and sharing of such personal information as specified in Section 3 and Section 7. Unless otherwise specified in applicable Program Terms we do not receive any direct monetary compensation from any third party for the use of your personal information in connection with Programs. We incur expenses when providing and operating these Programs. To the extent we create overall value from Programs for our business that could be directly or reasonably related to the value of customer information, an estimation of that value would be based on specific facts such as (1) whether and to what extent consumers take advantage of any Program offerings; (2) the expenses associated with the Program such as data analytics and marketing, (3) the expenses related to the collection, retention, processing and enhancement of consumers' personal information; and (4) all other expenses reasonably related to the Programs. While we do not assign a monetary value to the data we collect through the Programs, based on our reasonable good-faith estimate, the value we receive from your personal information by participating in the Programs is reasonably equal to the value of the discount or financial incentive we provide to participants in the Programs. For example, with respect to the Best Rewards and True Value Rewards loyalty Programs, a good-faith estimate of the value of a consumer’s data would generally be that the expenses related to the financial incentive program are approximately $5 for each 250 points that the consumer accrues, with the total value and expense depending on the quantity of points accrued.

You may opt-out of participation by ceasing to participate in a Program (including by cancelling your Account or opting out of the Texting Program), opting out of sharing or selling of your personal information as provided in Section 11, or by contacting us as provided in Section 23. Please note that operation of the Best Rewards and True Value Rewards loyalty Programs are reliant on the exchange of personal information between us and Stores regarding purchases you make using your Rewards Number, including purchases at a Store, to calculate loyalty rewards. Your decision to opt out of the sale or sharing of your personal information will result in termination of you participation in all loyalty Programs (both Best Rewards and True Value Rewards), and loss of any loyalty points and unused rewards.

21. POLICIES FOR CHILDREN

Do it Best Group does not sell Products ordered through our Services directly to anyone who we know to be under the age of 18, including children under the age of 16. Persons under 18 years old are not allowed to register for Accounts. Do it Best Group does not knowingly collect or use any personal information from persons under 13 years of age. No information should be submitted to the Site or Services by anyone under 13 years of age. If a child has provided our Services with personally identifiable information, we ask that a parent or guardian contact us as provided in Section 23.

22. LINKED SITES

Our Sites and Services may contain links to third-party websites, including Store operated websites (“External Sites”). We have no control over the privacy practices or the content of these External Sites, and we are not responsible for (and under no circumstances shall be liable for) the contents content or the privacy policies of those External Sites. You should check the applicable third-party privacy policy and terms of use when visiting any External Sites.

23. CUSTOMER CARE CONTACT INFORMATION:

Please click here for information on how to contact us.

Do it Best Corp.
1626 Broadway Suite 100
Fort Wayne, IN 46802
Privacy Administrator - Ecommerce
833.800.5906
privacypolicy@doitbest.com