PRIVACY POLICY

Effective Date: December 2023

This website is owned and operated by Robert Levy Associates, LLC (“RLA,” “us,” “we,” and “our”). All references to “RLA” herein means Robert Levy Associates, LLC, a State of Michigan Limited Liability Company. Your privacy and trust are very important to us. The purpose of this Privacy Policy is to describe how RLA collects, uses, and shares information that is collected about you through our website. Please read this Privacy Policy carefully to understand what we do and how we treat information that is collected about you through the Website. By using the Website, you are accepting the practices described in this Privacy Policy. If you have any questions or comments regarding this Privacy Policy, please contact us at rlevy@rlevyinc.com .

Changes to Our Privacy Policy

We may make changes to the Privacy Policy from time-to-time. We will notify you of any material changes by sending you an email or posting a notice on the home page of the Website. If you receive notification of a change in our Privacy Policy, you must review the new Privacy Policy carefully to make sure you understand our practices and procedures.

Information We Collect

Personal Information. Through the Website and the services offered on the Website, you can provide Personal Information, such as your name, billing address, mailing address, phone number, email address. By providing your personal contact information, you have authorized us to send you notifications or emails related to your order or regarding promotional and product information. You may opt out of receiving promotional or product information by clicking on the unsubscribe link found in our email communications.

Non-Personal Information. We also collect certain information automatically from you as you use the Website, such as your browser type, the URL of the previous website you visited, your ISP, operating system, and your Internet protocol (IP) Address.

No Information From Children Under Age 13. If you are under the age of 13, please do not attempt to place an order with us at the Website or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 13, please Contact Us, email us at rlevy@rlevyinc.com . Prospective users between the ages of 13 and 17 can only use the Website and services under their parents or legal guardian’s supervision. If you are between the ages of 13 and 17, you, your parent, or your legal guardian may request that we remove any of your information in our database and/or opt-out from receiving communications from us. If you wish to do so, please Contact Us, email us at rlevy@rlevyinc.com .

How We Collect and Use Your Information

Providing Information to Us. We collect Personal Information from you when you provide it to us. For example, if you purchase a product or register at a sale or on our sites, we may collect your name, mailing address, telephone number, and email address. If you sign up to receive email notifications, we will collect your email address.

Communications With Us.

If you communicate with us regarding the Website or services, we will collect any information that you provide to us in any such communication.

Personal Information. We use Personal Information primarily for our own business purposes, such as providing, maintaining, evaluating, and improving the Website and the services offered through the website, fulfilling requests for information, providing information about sales we are conducting and/or services that we provide, and providing customer support. For example, if you register with us, we will use the information that you provide us to communicate with you. Similarly, if you sign up to receive email notifications, we will use the email address you provide to send you the newsletters and product and sales updates.

Google Analytics. Information is also collected through Google Analytics to help analyze how users use the Website. The Google Analytics tool uses “cookies,” which are text files placed on your computer, to collect standard Internet log information and visitor behavior information in an anonymous form. The information generated by the cookie about your use of the Website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the Website and to compile statistical reports on Website activity for RLA. For more information regarding how Google Analytics protects your data, please visit Google’s website at www.google.com/analytics/learn/privacy.html.

Cookies. When you visit our Website we send one or more “cookies” to your computer or other device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that website to recognize your browser. Cookies may store unique identifiers, user preferences, and other information. You can set your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. We use cookies to improve the quality of the Website and services, including to store user preferences, to track user trends, and to provide relevant advertising to you.

Pixel Tags. We may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of the Website. A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies. A pixel tag can collect information such as the IP (Internet Protocol) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.

How We Share Your Information with Third Parties

Disclosure to Unaffiliated Third Parties. We may disclose your information for a variety of reasons including, but not limited to, to prevent an emergency, to prevent harm to others, to respond to legal requirements, to protect or enforce our rights and policies, to protect or enforce the rights of a third party, or as required or permitted by law (including, without limitation, to comply with a subpoena or court order).

Disclosure to Third Party Service Providers and Online Partners. We may contract with various third parties who help us provide, maintain, and improve the Website and the services. For example, if we use a third party to process payments made to us, and may subcontract out production, fulfillment, analytics, reporting or other operations. We also contract with several online partners to help manage, monitor and optimize our Website and services and to help us measure the effectiveness of our advertising, communications and how visitors use the Website. We cannot guarantee that such third parties will not disclose your information. We do not sell or rent your information with third parties for their promotional purposes. We have joint ventures on specific asset sale projects. We may provide our JV partners your opted in contact information to fulfill your request for information for those opportunities only.

Disclosure of Non-Personal Information. We may disclose your de-identified information, in aggregate form, to potential strategic partners, advertisers, investors, customers, and others.

Internet Advertising. We may use third party service providers to serve ads on our behalf across the Internet and sometimes on the Website. They may collect anonymous information about your visits to our Website, and your interaction with our products and services. They may also use information about your visits to this and other websites to target advertisements for goods and services.

Disclosure to Successors. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Website to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.

Your Consent. In addition to the sharing described elsewhere in this Privacy Policy, we will only share personal information with companies, organizations, or individuals outside of RLA when we have your consent to do so.

How We Protect Your Personal Information

Personal Information. The security of your Personal Information is important to us. We use industry standard physical, technical, and administrative security measures and safeguards to protect the confidentiality and security of your personal information. We do not take credit card or financial information, however when you enter sensitive information such as a personal information on our registration forms, we encrypt that information using secure socket layer technology (SSL). However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Reviewing and Making Changes To Your Personal Information

If you have questions about personal information we have about you or need to update your information, you can Contact Us, email us at rlevy@rlevyinc.com . You can opt-out of receiving marketing or promotional e-mails from RLA by using the opt-out or unsubscribe feature contained in the marketing or promotional e-mails.

International Privacy Practices

Using the Internet to collect and process your information may involve the transmission of information internationally. By providing us with your information you acknowledge and agree that we may store your information and transfer it to and from our servers located in the United States and throughout the world.

Accessing Third Party Websites

You may be able to access third party websites directly from the Website. This Privacy Policy does not apply when you access third party websites. We cannot control how third parties may use any information you disclose to them, so you should carefully review the privacy policy of any third party website you visit before using it or disclosing your information to its provider.

If we disclose your information to a third party in a manner that is not set forth in this Privacy Policy, you will be notified so that you can make an informed choice about sharing your information with that third party.

California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2017 sharing activities).

To obtain this information, please send an email message to info@rlevyinc.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

Questions and How To Contact Us

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, please contact us by email at info@rlevyinc.com or by sending certified mail to Robert Levy Associates, LLC, Attention: Legal Department, 905 South Boulevard East, Rochester Hills, MI 48307