PRIVACY POLICY

WELCOME!

B & B Trading Corporation (“B & B,” “we,” “us,” or “our”) recognize the importance of privacy and the need to protect the Personal Information provided to us. This Privacy Policy (the “Privacy Policy”) explains our data collection practices and use of your Personal Information. This Policy applies to our website and to information we collect offline (together, our “Service”).

Please read this Privacy Policy and our Terms of Use carefully before using the Service. We want you to be fully aware and confident of how your information is collected and used because we appreciate the trust you have placed in us. By using the Service or otherwise providing Personal Information to us, you agree to the Service’s Terms of Use and consent to B & B’s data collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service. If you do not agree and consent, please discontinue use of the Service.

WHAT PERSONAL INFORMATION DO WE COLLECT & WHY DO WE COLLECT IT?

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

The chart below summarizes the types of Personal Information we may collect from you and why we collect it:

CATEGORY OF PERSONAL INFORMATION / EXAMPLES / PURPOSE(S) FOR COLLECTION, USE, AND DISCLOSURE:

Contact Information Name, title, alias, professional/employment information (employer name, your position title, etc.), postal address, phone number, fax number, email address, driver’s license or state ID card number

• To fulfill and deliver your orders

• To maintain your account with us

• To communicate with you, including about our products and your orders, updates to our terms and policies, and to obtain your feedback

• Processing returns and refunds

• For product warranties

• To send you marketing materials and advertisements

• To allow you to participate in promotions, sweepstakes, and contests

• To detect and prevent fraud against you and/or us

Other Identifiers Username and password for our Services, security question/answer combinations, signature, social security number, social media usernames

• To maintain your account with us

• To recognize you when you use our Services

• To allow you to participate in promotions, sweepstakes, and contests

• To detect and prevent fraud against you and/or us

Payment Information Credit card number, financial account number, or other payment information used to purchase our products

• To process your orders and any returns/refunds, including allowing you to purchase on credit

• To detect and prevent fraud against you and/or us

Commercial Information Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, information from surveys, promotions and product reviews

• To fulfill and deliver your orders

• Processing returns and refunds

• For product warranties

• To provide you with appropriate products and recommendations

• To help you find relevant products more quickly

• To provide customer service and support

• To allow you to participate in promotions, sweepstakes, and contests

• To improve our websites, apps, products, marketing and advertising

Geolocation Data Your physical location based on information you provide directly

• To fulfill and deliver your orders

• Processing returns

• For product warranties

Communications with Us The contents of your communications with us via phone, email, text message, chat, or other means (such as survey responses, product reviews, and comments on our blog and social media pages)

• To communicate with you, including about our products and your orders, to provide answers to your questions, and to obtain your feedback

• To provide customer service and support

• Processing returns and refunds

• For product warranties

• To improve our websites, apps, products, and marketing

• To allow you to participate in promotions, sweepstakes, and contests

• To detect and prevent fraud against you and/or us

Inferences About You from Any Other Category of Information We Collect Information reflecting your preferences, characteristics, trends, or attitudes

• To provide you with appropriate products and recommendations

• To improve our websites, apps, products, and marketing

• To provide you with a better website or app experience

• To detect and prevent fraud against you and/or us

We may use and share information for any purpose if it is publicly available, de-identified, or aggregated with other information so that it can no longer identify you.

HOW DO WE COLLECT PERSONAL INFORMATION?

We collect your Personal Information through various means, including when you directly provide it to us through our website, by email or over the telephone. In some instances, you may be able to choose what information to provide, but sometimes we require certain information from you to use features of our Service.

INFORMATION THAT YOU PROVIDE

We collect Personal Information about you directly when you:

• Register or maintain an account with us

• Purchase products or services from us

• Apply to purchase products on credit

• Exchange communications with us by mail, email, phone, text, etc.

• Obtain customer service or technical support

INFORMATION COLLECTED AUTOMATICALLY

B & B, our Service Providers, and/or third-party services also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device).

The methods used to collect Usage Information include:

• Cookies. We use cookies and other tracking technologies (such as web beacons) to collect and store information about your interactions with our websites, including information about your browsing behavior. Our websites also support third-party cookies placed by our Service Providers, affiliates, and advertising partners.

Cookies are small files that a website transfers to your device through a web browser that enable the site’s or a third party’s systems to recognize your device and to capture and remember certain information. Web beacons (also known as tracking pixels) are tiny graphics embedded invisibly on a webpage or in an email that may be used to deliver or communicate with cookies, to count users who have visited certain pages, and to understand usage patterns. In general, our websites use cookies and other tracking technologies as follows:

• Where necessary to run our websites, for example by allowing you to log in and add items to your cart

• To optimize the functionality of our websites, including by personalizing content for you, greeting you by name and remembering your preferences (e.g., your choice of language or region)

• For analytics purposes—for example, to help us understand how our websites are used, to see what products most interest you, and determine how best to market our products to you. More information on website analytics is provided below.

• For purposes of ad targeting and marketing. These cookies collect information about your browsing behavior on our websites in order to show you interest-based advertising when you visit other websites or use social media.

• To determine if you open or act upon our email messages. Information on unsubscribing from our commercial email communications is provided below.

• To obtain information about your interactions with our online advertisements, such as whether you clicked on an ad and the website where you may have seen the ad

Cookies vary in how long they last. “Session cookies” terminate shortly after you terminate your internet session. “Persistent cookies” are stored on your device until a set expiration date. We use both session cookies and persistent cookies on our websites.

WHEN WILL WE SHARE YOUR INFORMATION?

We may disclose your Personal Information for any purposes not inconsistent with this Privacy Policy, our written statements at the point of collection, or applicable law. In general, we share Personal Information as follows:

• As necessary, for the following purposes: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain

• With our insurers and professional advisers for the purposes of managing risks, obtaining professional advice, exercising or defending against legal claims, etc.

• With third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding)

YOUR CHOICES ABOUT TRACKING AND COMMUNICATIONS FROM US

Cookies and Tracking Technologies

Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Please review your browser’s Help menu for instructions, or visit www.allaboutcookies.org for more information. Please note that, if you disable all cookies, some features of our websites may not function properly.

Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. We do, however, respond to the Global Privacy Control (“GPC”) signal for California residents wishing to opt-out of the “sale” of their Personal Information. For more information, please see the California-specific section of this Policy, below.

Email Communications

You may unsubscribe from our marketing email communications by clicking the “unsubscribe” link found in every commercial email we send, or by sending a request to unsubscribe to info@bandbtrading.net. If you opt-out of our marketing email communications, we may still send you email messages related to your account or purchases with us. Unsubscribing from our marketing communications will not affect the level or quality of service we provide to you.

SECURITY

We work hard to protect B & B and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular, we implement commercially reasonable measures to protect Personal Information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and B & B does not guarantee the security of your information collected through the Service. You are responsible for maintaining the confidentiality of your passwords and the security of your devices. If you suspect any unauthorized activity associated with your account, please report that activity to us immediately.

INTERNATIONAL VISITORS

Our Service is directed solely to residents of the United States. If you access the Service from outside of the U.S., please be aware that Personal Information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any Personal Information constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. as set forth in this Privacy Policy.

CHILDREN’S PRIVACY

The Service is intended for a general audience and not directed to children less than 16 years of age. We do not knowingly collect or sell the Personal Information of children under the age of 16. If we learn that we possess information from a child under the age of 16, we will delete such information in accordance with the Children’s Online Privacy Protection Act (“COPPA”) or other applicable laws (such as the California Consumer Privacy Act). If you are a parent or guardian and you believe that your child under the age of 16 has provided us with Personal Information, please contact us.

NEVADA PRIVACY NOTICE

Nevada residents may opt-out of the sale of “covered information” to third parties, including but not limited to name, address, social security number, telephone number, email address, and other information through which a person may be contacted. Our uses of your Personal Information are not sales under Nevada law. If you have any questions or if you would like to receive notice by email in the event we should engage in sales of Personal Information under Nevada law in the future, please email us at info@bandbtrading.net.

YOUR CALIFORNIA PRIVACY RIGHTS

This section supplements the other parts of our Privacy Policy, and provides additional information for California residents pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), and other applicable California laws and regulations.

California Notice of Personal Information Collected.

The Personal Information we collect about you, the sources from which we collect it, and how we use and disclose it are described elsewhere in this Privacy Policy. Here is how the types of Personal Information we collected within the past 12 months fit within the categories defined by the CCPA:

i. Identifiers—including your name, alias, title, user ID, email address, email communication preferences, postal address, phone number, fax number, signature, social security number driver’s license or state ID card number, login information for our Service, IP addresses

o Sensitive Personal Information within this category includes social security number, and driver’s license or state ID card number

ii. Personal Information described in Cal. Civ. Code § 1798.80(e)—overlaps with the identifiers we collect, and also includes payment information

iii. Characteristics of protected classifications under California or federal law—we collect your birthdate, age, gender, and languages spoken

iv. Commercial information—including purchase history, products or services purchased, obtained or considered, and other purchasing or consuming histories or tendencies

v. Internet or other electronic network activity information—including device and usage information, browsing history, search history, and information regarding your interactions with our websites, apps and advertisements, email engagement activity, information from cookies and other tracking technologies, and website analytics information

vi. Geolocation data—geolocation data inferred from your IP address or mobile device location

o Sensitive Personal Information within this category includes precise geolocation, which is collected based on your mobile device location when you use our mobile apps

vii. Audio, electronic, visual, thermal, olfactory, or similar information—audio data collected when you call our customer service numbers; security camera footage in our stores

viii. Professional or employment related information—such as your employer and position if you choose to provide that information to us

ix. Inferences drawn from other Personal Information—preferences, characteristics, predispositions, behavior, or attitudes based on other Personal Information collected about you

x. We also collect the contents of your communications with us, which may include Personal Information that does not necessarily fit within one of the specific categories defined by the CCPA

Retention of Personal Information

We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

• Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;

• Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;

• The information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or

• We are otherwise required or permitted to keep your information by applicable laws or regulations.

Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.

Disclosures, Sharing, and Sales of Personal Information

We may disclose to our Service Providers and Contractors any category of Personal Information we collect in order to further the business purposes described in this Privacy Policy, which include:

• Auditing related to ad impressions

• Ensuring security and integrity of Personal Information

• Debugging to identify and repair errors that impair existing intended functionality

• Short-term, transient use, including, but not limited to, non-personalized advertising

• Performing services on our behalf

• Providing advertising and marketing services (except for cross-context behavioral advertising)

• Undertaking internal research for technological development and demonstration

• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us

• Processing, maintaining, or collecting Personal Information on our behalf

• Detecting or protecting against malicious, deceptive, fraudulent or illegal activity

• Internal use by the service provider

The categories of Service Providers and Contractors to which Personal Information is disclosed include order processing and delivery vendors, customer service providers, analytics and website support vendors, credit bureaus, marketing service providers, auditors, and service providers that help support our website, mobile apps, and business operations. For more information, please see the section of this Policy titled When Will We Share Your Information?

Except for payment information, social security number, and driver’s license/state ID card number, we may also sell or share with third parties any of the categories of Personal Information we collect. Under California law, a “sale” of Personal Information does not necessarily involve an exchange of money. Instead, the term also includes disclosures of Personal Information to third parties under circumstances where the third parties may use the information for their own purposes. The third parties to which this information may be sold or shared include advertising and marketing companies, social media platforms, other businesses interested in marketing their products and services to you, data cooperatives and exchanges, and data brokers. Our purposes for selling and sharing Personal Information relate to certain types of marketing and advertising, as further described above. We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

How to Use Your Rights Under the CCPA

If you are a California resident, you have the right to submit certain requests relating to your Personal Information. To exercise any of these rights, please submit a request by calling us at 617.442.1400.

Please note that, if you submit a request to know, request to delete, or request to correct, we will need to take reasonable steps to confirm that the person submitting the request is the person to whom the information relates (or his or her authorized agent). We generally ask you to provide 2-3 pieces of Personal Information about you in order to verify your identity. The specific steps taken to verify the identity of the requesting person may vary based on the nature of the request, including the type, sensitivity and value of the information involved, the risk of harm posed by unauthorized access, deletion or correction, the likelihood of fraud, the robustness of Personal Information provided to verify your identity, the nature of our business relationship with you, and available technology for verification.

You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will still need to verify your identity directly with us. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.

Right to Opt Out of Sale and Sharing of Personal Information. Although we do not sell your Personal Information in exchange for money, some of the ways in which we share your Personal Information for advertising or marketing may be considered a “sale” or “sharing” under California law. To opt out of the sale of your Personal Information or sharing for cross-context behavioral advertising, please click here. If you choose to use the Global Privacy Control (GPC) browser signal, you will be opted out of cookie-based sales or sharing of Personal Information, and will need to turn it on for each browser you use. To submit a request to opt out of offline sales and sharing, to info@bandbtrading.net.

Right to Know. If you are a California resident, you have the right to request more information regarding the following:

1. The categories of Personal Information we have collected about you, including

a. The categories of sources from which the Personal Information was collected

b. Our business or commercial purposes for collecting, selling, or sharing your Personal Information

c. The categories of recipients to which we disclose Personal Information

d. The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information

e. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information

2. The specific pieces of Personal Information we have collected about you

3. A list of the third parties to which we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding calendar year for third-party direct marketing purposes

Please note that due to the different requirements of the applicable laws, our response times may vary depending on the specific type(s) of information sought. We respond to all verifiable requests for information as soon as we reasonably can and no later than legally required.

Right to Request Deletion of Your Personal Information. California residents have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.

Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Limit Use and Disclosure of Sensitive Personal Information. You may direct us to limit the use and disclosure of your Sensitive Personal Information to uses/disclosures that are reasonably necessary to provide our goods and services, or as needed: to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; for short-term, transient use, including for non-personalized advertising; to perform services on behalf of the business; and to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices. To limit our use of your Sensitive Personal Information, please click here.

Right to Non-Discrimination. If you choose to exercise any of the privacy rights conferred by the CCPA, you also have the right not to receive discriminatory treatment by us. This means that, consistent with California law, we will not deny providing our products or services to you, charge you different prices or provide a different level or quality of products or services to you unless those differences are related to the value of your Personal Information.

CHANGES TO THIS POLICY

By using our Service, you consent to the terms of this Privacy Policy and our Terms of Use. We may change our Privacy Policy from time to time. Your use of our Service indicates your consent to the privacy policy posted at the time of use.

On January 1, 2023, we changed our Privacy Policy to clarify the types of information we collect about you, the ways we collect your information, and how we use and share your information. We updated our Privacy Policy to use the same standards across all of our brands, websites, and apps. And we updated the parts of our Privacy Policy that explain the rights of California and Nevada residents.

HOW TO CONTACT US

If you have any questions about this Privacy Policy, please contact B & B at info@bandbtrading.net, or at:

B and B Trading Corporation

1033 Turnpike Street

Stoughton, MA 02072

Attention:

Anthony Capozzi

Chief Financial Officer