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Privacy Policy

California Notice at Collection: If you are a California resident, see the U.S. States Privacy Rights section below for important information about your rights under California law.

NEJ, Inc. d/b/a Wholesale101.com (“Wholesale101.com”, “we”, “us”, or “our”) respects the privacy of our users. This Privacy Policy (the “Policy”) explains the type of personal information that we collect and how we collect, use, access, disclose, safeguard, store and otherwise process your personal information (i.e. any information that personally identifies you such as your name and contact information), when you interact with us through the Wholesale101.com website, wholesale101.com (“Site”) including when you register for and utilize an account (“Account”) on the Site, purchase palleted overstock merchandise (“Merchandise”), and when you utilize our customer service features through email, mail and phone (“Customer Service”). The Site, Account and Customer Services are collectively referred to as the “Services”. This Policy does not apply to use or interaction with other websites operated by NEJ, Inc. or if you are a job applicant or employee of NEJ, Inc.

Please read this Privacy Policy carefully. You can download a printable copy of this Policy here. If you do not agree with the terms of this Policy, please do not access or use the Services. Your clicking to accept this Policy when presented with the option or your use of the Services is your acknowledgement and agreement (i) to the terms of this Policy and any other applicable agreement that may be provided together with the Services, and (ii) that we have your permission to collect and process your information as described in this Policy. If you’re agreeing to this Privacy Policy on behalf of an organization or entity, you represent and warrant that you are authorized to agree to this Policy on behalf of that organization or entity and to bind them to these provisions (in which case, the references to “you” and “your” in this Policy, except for in this sentence, refer collectively to you personally and to that organization or entity).

We may need to make changes to this Policy as privacy laws change, our Services evolve, or we add or change service providers among other things. As a result, we reserve the right to make changes to this Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Policy. Any changes or modifications will be effective immediately upon posting the updated Policy on our Site at www.wholesale101.com. Your continued use of the Services following the posting of changes to these terms means you accept the updated Policy.

 

INFORMATION WE COLLECT

1) Information we may collect directly from you:

· Personal Information that identifies you, such as your name and contact details including phone number, email address, street/mailing address, zip code only, telephone or fax number, and geolocation only.

· Account Registration Information, such as information provided by you when you register for an account, including User ID, log-in details, security questions and answers, and passwords;

· Financial, Payment and Commercial Data, such as name, billing address and payment card details, including credit card numbers, expiration dates, and security codes (which are collected by our third-party payment processor(s) on our behalf) in the event you purchase any Merchandise from us as well as any history and records of any Merchandise inquired about, obtained or other purchase information;

· Marketing and Communications Data, including your preferences for receiving our marketing communications and details about your engagement with them, or your interest in our Services or any Merchandise we sell; and,

· Other personal information you submit to us through communications, Customer Support exchanges, our “Contact Us” link, surveys, a competition, reporting a problem, email, or otherwise.

2) Information we may obtain about you from your usage, from others or by automated means:

· Derivative Data and Usage Information, such as technical information related to your use of the Site, including device name and type, IP address, other set up data, operating system, browser type, access times, pages viewed, other interactions with the Site, including your Account, which are automatically collected and stored in log files;

· Geolocation and GPS Data, including the physical location of your device(s), including your mobile device;

· Market and Research Information, such as IP address, social media handle, or other online identifiers of a person, email address/mobile number if used for direct marketing and name and address, browser/web history data and preferences expressed through selection/viewing/purchase of Merchandise, analytics and profiles based on the data collected on you, and

· Cookies, web server logs, web beacons and other technologies (See also Cookies Section below).

 

HOW WE USE THE INFORMATION WE COLLECT

We may use your personal and other information to:

· Manage our contractual relationship with you, including providing you with information regarding our Merchandise, billing and order information, purchased Merchandise, handling claims, troubleshooting, system maintenance, hosting and providing Customer Support services;

· Set up and manage your Account and profile, including to contact you regarding your Account and any purchased Merchandise;

· Provide, develop and improve our Services, including delivering our Services to you and for additional purposes that help us to develop and improve the quality of our Services (including as part of the development of any new products and services);

· Facilitate communication, between us;

· Comply with a legal, regulatory or relevant industry standard obligation, including this Policy, intellectual property infringement, or enforcing our Terms and Conditions, or other contracts you have entered into with us;

· Protect against, identify and prevent fraud or other criminal activity, claims and other liabilities, that we may notice based upon any activity on your Account or your use of the Services;

· Monitor your use of the Services, including your Account, as part of any routine support and maintenance of the Services;

· Improve the security and other related system and network functions including preventing misuse;

· Perform analytics, including trend and financial analysis, market and consumer research, anonymization and aggregation of personal information; and

· Conduct marketing activities in accordance with applicable laws. Depending on your jurisdiction, you will either be required to opt in to receive marketing communications or opt out by using the unsubscribe link in any marketing materials you receive via email from us or by contacting us at the link provided on our website.

 

HOW WE SHARE YOUR INFORMATION

1) We share your personal information in the following limited situations:

· With your consent, including with third parties to facilitate shipping or providing Merchandise to you;

· With our Service Providers, who facilitate us in providing the Services to you including processing, storage, and technical assistance, including our third party payment processors, whereby we have entered into contracts with such service providers which include limitations on their use of certain of your information and only as necessary to provide these Services to us/you;

· With Third-Party Service Providers for Web and App Analytics, including automated technology we may use to collect and analyze your information, including personal information to help us understand your use and optimize your customer experience (please see our section on Cookies to learn more);

· With Professional Advisors and Governmental Authorities, if we believe in good faith that disclosure, access, use or preservation of such information is necessary to (i) meet any applicable law, regulation, legal process or governmental request; (ii) enforce or investigate your compliance with the terms of any of our contracts or policies we have with you for potential violations; (iii) protect against physical, financial or other harm against the rights, safety or property of you, us, or any third-party; and, (iv) investigate fraud, technical, security or other operational issues; and

· In connection with Corporate Transactions, meaning changes to our corporate structure due to sale, transfer, merger or other reorganization of our company during which your personal information may be among the items sold or transferred.

2) We may share your non-personal information (including aggregated or anonymized data) with:

· Third-Party Business Partners and Service Providers, and

· Other Users, to help us improve the Services or raise awareness about safety issues.

We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We may make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business. We will not attempt to re-identify any such data, except as permitted by law.

 

YOUR CHOICES

In this section, we describe the rights and choices available to all users regarding their personal information. Users who are located in certain locations, e.g., California, can find additional information about their rights below.

· Access or update your information. If you have registered for an Account with us, you may review and update certain account information by logging into the account or by contacting us.

· Opt-out of communications. If you no longer wish to receive marketing-related communications, you may opt-out of receiving these emails by clicking “Unsubscribe” found in emails we send you. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

· Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.

Declining to provide information. We need to collect personal information to provide certain Services and sell you Merchandise. If you do not provide the information we identify as required or mandatory, we may not be able to provide those Services or sell the Merchandise to you.

 

THIRD PARTY WEBSITES

Our Services may include links to third-party applications, products, services, or websites. If you access those links, you will leave our Services. Wholesale101.com does not control these third-party sites or their privacy practices, which may differ from Wholesale101.com’s practices. This Policy does not cover the personal information you choose to provide to or that is collected by these third parties. You are encouraged to review the privacy documentation of any third-party site you interact with before you allow them to collect and use your personal information.

Wholesale101.com may also provide social media features on the Site, such as the Facebook, Instagram, LinkedIn or X buttons, that enable you to share information with your social networks or to interact with Wholesale101.com on various social media websites. Your use of these features may result in the collection or sharing of information, including personal information, about you depending on each specific social media website. This may include your IP address, which page you are visiting on our Site, and a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

 

HOW WE SECURE YOUR INFORMATION

The security of your information is important to us. Wholesale101.com takes a number of precautions — including administrative, technical, and physical measures — designed to safeguard your personal information

against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

Wholesale101.com is located in the United States, and as such, all personal information will be accessed and stored there. Wholesale101.com does not do business outside of the United States. Where required, we have put in place appropriate safeguards with our affiliates, service providers, contractors, distributors and other business partners and agents to manage transfers of personal information in a manner that addresses security protocols.

For more information on our security practices, please contact us at [insert email address].

 

RETENTION OF YOUR PERSONAL DATA

We retain your personal information as follows:

The period during which we store your personal information varies depending on the purpose for the processing:

· For the provision of our Services, for so long as you are a customer, Account holder, or use the Services.

· For marketing purposes, until you have opted out of receiving further direct marketing communications in accordance with applicable law.

· In all other cases, we store your personal information for as long as is needed to fulfill the purposes outlined in this Policy or such retention period as required by law, following which time it is either anonymized (where permitted by applicable law), deleted or destroyed.

 

USE OF COOKIES AND OTHER DATA COLLECTION TOOLS

Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information.

“Cookies” are small text files that are placed on your device by a Web server when you access a website. To enable our systems to recognize your browser or device and to provide and improve the Services, we may use both session Cookies and persistent Cookies. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize our Services. Unlike persistent Cookies, session Cookies are deleted when you log off and close your browser.

Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party service providers that we engage (including third-party advertisers) may also place their own Cookies on your device. Note that this Policy covers only our use of Cookies and does not include use of Cookies by such third-parties.

“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be used for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Site, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

We support the development and implementation of a standard “do not track” browser feature that provides customers with control over the collection and use of information about their web-browsing activities.

 

MINORS

You must be at least 18 years old (or equivalent minimum age in the jurisdiction where you reside) to use the Services.

 

CONTACT INFORMATION

If you have any questions about this Policy or if you would like us to update information we have about you, change your preferences, or exercise applicable data protection rights, please contact us at:

Email: info@wholesale101.com

Phone: 203.463.3369 | 203.463.3338 | 203.463.3329

Mailing Address:

Wholesale101.com

170 Pinesbridge Road

Beacon Falls, CT 06403

 

U.S. States Privacy Rights

Last updated: May 2024

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or any other state that has enacted applicable data protection regulations (the “Supplemental States”), the following provisions may apply to our processing of personal information as described in our Privacy Policy. Please note that Wholesale101.com may not be subject to certain of these Supplemental States regulations, but we provide the rights listed below with respect to your personal information.

Wholesale101.com values the privacy of our customers, users and Site visitors and we take measures to implement reasonable security controls for the protection of our clients’ information. This section does not apply to our collection, use, and sharing of personal information of our job applicants and employees.

Your Rights. If you are a resident of a Supplemental State, you may have certain rights related to your personal information. The rights listed below are not absolute, and we may be entitled to refuse requests, wholly or in part, where exceptions under applicable law apply. Your rights may include:

· The right to request access to personal information that we have collected or retained about you. If requested, we shall provide you with a copy of your personal information which we collected as permitted by the Supplemental States privacy laws. You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another entity (“data portability”).

· The right to request to know:

o specific types or categories of personal information we have collected about you;

o categories of sources from which the personal information is collected;

o our business or commercial purpose for collecting, sharing, or selling personal information; and

o categories of third parties with whom we share personal information.

· The right to request that we delete personal information about you which we have collected from you.

o In certain circumstances, you have the right to request that we 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 (instructions and description below), we will delete, and, as applicable, direct our service providers to delete, your personal information from our records, unless an exception applies.

o We may deny your request to delete your personal information if retaining the information is necessary for us or our service providers, subject to certain exemptions based on your state of residence.

· The right to opt-out/do not sell or share your personal information.

o You may have the right to opt-out of selling or sharing your personal information with third parties for some purposes, including sharing that may be defined as a sale under applicable Supplemental States laws. We do not sell your personal information in a traditional sense, that is, for monetary value. We do disclose personal information for business purposes as outlined in our “How we Share Your Information” section of our Privacy Policy.

o You also may have a right to opt-out of the use of automated decision-making technology.

· The right to request that we do not share or disclose your sensitive personal information.

o You have the right to limit how your sensitive personal information is disclosed or share with third parties. We will not share your sensitive personal information without your consent.

· The right to request correction or rectification.

o In certain circumstances, you have the right to request correction of any inaccurate personal information.

Exercising your rights: To submit requests to exercise any of the foregoing rights with respect to you personal information, please contact us at the contact information provided below. To exercise your right to opt-out of the “sale” or “sharing” of your personal information, contact us at info@wholesale101.com.

Subject to applicable Supplemental States laws, we may not discriminate against you because of your exercise of any of the above rights under the Supplemental States laws, including by:

· Denying you Services;

· Charging different prices or rates for Merchandise, including through the use of discounts or other benefits or imposing penalties;

· Providing you a different level or quality of Services or Merchandise; or

· Suggesting that you will receive a different price or rate for Merchandise or a different level or quality of Merchandise.

Verification of identity; authorized agents: In order to process any of the foregoing rights with respect to your personal information, we reserve the right to confirm your residency in the applicable Supplemental States, and we will need to verify your identity. To do so, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.

In some instances, your authorized agent may make a request on your behalf. We will need to verify your agent’s identity and be in receipt of a valid power of attorney as required under applicable Supplemental States law(s).

Personal Information that we collect, use, and disclose. We summarize the personal information we collect by reference below to both categories defined in the “Information We Collect” section of the Privacy Policy. In view of the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively the “CCPA”), we anticipate that we will collect the following categories of personal information from customers and Site visitors. Information you voluntarily provide to us may contain other categories of personal information not described below.


Indentifiers

Name, address, email address, zip code, telephone number, geolocation

Disclosure for business purposes:
1. Service providers;
2. Governmental entities; and/or
3. Other parties to comply with legal obligations.

“Share”/”Sell”: business and marketing partners.

Account Information/Commercial Information

User ID, log-in, security questions and answers; passwords; billing information; information about Merchandise inquired about or purchased

Disclosure for business purposes:
1. Service providers;
2. Governmental entities; and/or
3. Other parties to comply with legal obligations.

“Share”/”Sell”: business and marketing partners.

Internet Usage Information

Technical information related to use of Site, IP address, operating system, access information

Disclosure for business purposes:
1. Service providers;
2. Governmental entities; and/or
3. Other parties to comply with legal obligations.

“Share”/”Sell”: business and marketing partners.

Geolocation Data

Physical location of your device (including mobile device)

Disclosure for business purposes:
1. Service providers;
2. Governmental entities; and/or
3. Other parties to comply with legal obligations.

“Share”/”Sell”: business and marketing partners.

Market/Research Information

Your preferences for receiving marketing communications, engagement with marketing communications; IP address, social media handle, email address/mobile number

Disclosure for business purposes:
1. Service providers;
2. Governmental entities; and/or
3. Other parties to comply with legal obligations.

“Share”/”Sell”: business and marketing partners.

Biometric information

Not collected

N/A

Data derived from the above

Inferences

Disclosure for business purposes:
1. Service providers;
2. Governmental entities; and/or
3. Other parties to comply with legal obligations.

“Share”/”Sell”: business and marketing partners.

Use of Personal Information. We may use or disclose the personal information we collect for one or more of the purposes provided in the “How we use the Information we Collect” and the “How we Share & Secure Your Information” sections of our Privacy Policy.

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.

Changes to our Privacy Policy. We reserve the right to amend this U.S. Privacy Rights section at our discretion and at any time. If we materially change this U.S. Privacy Rights section, we will post the updated notice on our Services and update the notice’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

If you have any questions or comments about this U.S. Privacy Rights section, the ways in which we collect and use your personal information, your choices and rights regarding such collection or use, or wish to exercise your rights, you may contact us at:

Email: info@wholesale101.com

Phone: 203.463.3369 | 203.463.3338 | 203.463.3329

Mailing Address:

Wholesale101.com

170 Pinesbridge Road

Beacon Falls, CT 06403