Privacy Commitment

This policy defines the commitment of Accoutrements LLC d/b/a Archie McPhee (“Archie McPhee”) to protect the privacy of personal information that is collected or used by Archie McPhee in the course of conducting Archie McPhee business. The scope of this policy includes the collection and use of employee, customer, supplier, and other-third party personal information. On a global basis, Archie McPhee will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this policy.

We respect the privacy rights of individuals.

Archie McPhee takes privacy seriously and is committed to complying with legal requirements regarding the privacy of personal information. Archie McPhee will, from time to time, review its personal information collection, use, and disclosure practices in order to assure compliance with laws and regulations.

We give notice of personal information collection.

Archie McPhee will give notice consistent with applicable law when personal information is collected. All notices will explain the need for the information and describe how the information will be used.

We get explicit consent for sensitive information.

To the extent required by applicable law, Archie McPhee will maintain procedures to assure that sensitive information is collected with explicit consent and/or opting in.

We process and distribute information consistent with our Privacy Notice.

Archie McPhee will collect and use personal information consistent with the Privacy Notice that has been provided. However, Archie McPhee may decide to remove identifiable features from collected personal information, and the resulting information may then be used for statistical, historic, scientific, or other purposes, consistent with applicable law.

We provide individuals a way to access and correct their information.

Archie McPhee will maintain commercially reasonable procedures consistent with applicable law for individuals to gain access to their collected personal information and, when appropriate, correct any information that is inaccurate or incomplete, or have their personal information deleted.

We provide information security.

Archie McPhee will use commercially reasonable efforts to maintain the security of personal information and to protect the integrity of such information.

We require others who process Archie McPhee data to comply with applicable law.

Archie McPhee will require others who acquire data from or provide data to Archie McPhee, including those engaged to provide support services, to appropriately protect personal information.

We will disclose personal information when required by law or court order.

Archie McPhee will, as permitted or required by law or court order, collect, use, transfer, and/or disclose personal information pursuant to procedures that do not require giving notice (for example, in connection with law enforcement investigations).

We provide a way to process complaints.

Archie McPhee will publish the procedures for responding to complaints regarding potential deviations from its established procedures for protecting personal information.

We align our human resources processes with this policy.

Archie McPhee will align its human resources processes, policies, practices, and guidelines to comply with this policy.

We maintain the flexibility to change this policy.

Archie McPhee reserves the right to modify and update this policy or its related business practices at any time.