Ajax Turner Company, Inc. (“Ajax Turner,” “Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it through the practices described herein. This Privacy Policy (“Privacy Policy” or simply “Policy”) explains our information collection practices and the rights and choices that you may have in relation to how we collect, use, retain, and disclose your Personal Information when you visit our website at https://ajaxturner.com/, engage us for our services, or otherwise interact with us through channels where this Privacy Policy is posted (collectively, the “Services”). Unless otherwise defined in this Privacy Policy, the terms used herein have the same meaning as in our Terms of Use.

Please read this Privacy Policy carefully to understand our policies and practices for collecting, using, and disclosing your Personal Information. This Policy may change from time to time (see Changes to This Policy), so please check the Privacy Policy periodically for updates.

Our website may contain links to external websites, plug-ins, services, and social networks managed by third parties. When you click on those links or enable these connections, the third parties involved may collect or share information about you. Because we do not control their privacy practices, we encourage you to review each organization’s privacy policies before providing any information. This Policy also notes that we may receive information about you from third parties; however, it does not apply to the ways those parties collect or process your data. Each third party maintains its own information collection practices. We recommend that you read their privacy policies carefully, and if you wish to exercise any rights over data held by those parties, you should contact them directly.

TABLE OF CONTENTS 

I. Information We Collect 

II. How We Use Your Information

III. Disclosures of Your Information

IV. Data Security and Retention

V. Services From Other Parties; Interest-Based Advertising

VI. Changes to this Policy

VII. Contact Us

I. Information We Collect and How We Collect It

We collect Personal Information (1) that you provide directly to us, (2) from your Device, Internet, and Network Activity, and (3) from other sources, as detailed below. For purposes of this Privacy Policy, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer—including information obtained through Device, Internet, and Network Activity. Information derived from Device, Internet, and Network Activity encompasses data that we, our Service Providers, and our other business partners collect about how you interact with our Services online.

Information You Provide Directly to Us

As a visitor to the website or an accountholder with Ajax Turner, you may provide us with the categories of Personal Information below in the course of our business relationship with you. We may collect the following categories of Personal Information from you in the course of our business, including through your use of the Services or when you contact us, subscribe to our communications or otherwise request information from us:

· Identifiers and Contact Information, such as name, email address, mailing address, company affiliation, phone number, copies of your certificate of resale and/or other Tennessee related alcohol permit(s), service requests/inquiries, or information you provide by filling in forms on our website.

· Geolocation, such as general geolocation information through your ZIP code or IP address.

· Transaction Information, such as your fulfillment order history. You may also need to input certain financial information before signing up as an accountholder or placing an order through us.

· Account Information, such as your username for your account with us.

· Inferences or preferences we learn or infer about you from other information we have collected about you.

· Other Information that you choose to share with us.

Device, Internet, and Network Activity Information

Personal Information derived from Device, Internet, and Network Activity we collect may include:

Device Data, such as information about your computer, phone, tablet, or other device you use to access our website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, device and/or browser type, hardware model, internet service provider and/or mobile carrier, operating system, mobile platform, and system configuration information.

Log and Usage Data, including service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our website and which we record in log files. Depending on how you interact with us, this log data may include information about your activity on the website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports, sometimes called “crash dumps” and hardware settings).

Cookies and Other Tracking Technologies, such as first party and third-party products and services to gather traffic statistics using cookies, pixels, or web beacons. A cookie is a small piece of information stored on your device that helps websites and servers recognize you. Ajax Turner, our Service Providers, and other third parties may also use other tracking technologies such as pixels, or transparent GIF files, for website management and visitor tracking.

Some of the technologies we use on our website are strictly necessary for functionality of the site. Others improve functionality but are not strictly necessary. Some cookies help improve the performance of our website (such as by gathering analytics data), while others help provide targeted advertising services to you (like ads that you may be interested in). Some cookies may be used to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Examples of cookies and other tracking technologies we may use include:

· Necessary Cookies. We use these cookies to make our site function properly.

· Preference Cookies. We use preference cookies to remember your preferences and various settings. Preference cookies remain on your computer or device until you delete them, or they are otherwise removed upon expiration.

· Statistics Cookies (Analytics Cookies). Statistics cookies help us measure the performance of our website, and the usefulness of the content it displays. They also help us analyze website usage patterns. As an example, we use Google Analytics to collect and analyze information about our Services. This service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ or opt out via https://tools.google.com/dlpage/gaoptout/.

· Marketing Cookies. We permit certain third-party business partners and advertisers to collect Personal Information through cookies or other similar technologies placed on our website. These companies may use the Personal Information collected through these cookies to track your behavior on our website, gather information about your use of our website, and other online services over time and across different businesses’ websites and services. Additionally, some companies may use information collected to deliver targeted advertisements on behalf of us or other companies, including on other applications, websites, or online services. We are not responsible for the functioning of cookies and other technologies used and placed by third parties on your device. We do not always control third parties’ collection or use of your information to serve targeted advertising. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

· Pixel Tags, Web Beacons, and Transparent GIFs. Pixel tags and web beacons are small graphic images placed on our website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages.

· Other Technologies. We collect many different types of information from other technologies to improve the quality of our website and the Services we provide. For example, we may collect usage data and other information about the device you use to access our websites, your operating system and/or mobile device type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located.

Strictly necessary cookies are enabled on our website by default. For information about how we respond to web browser signals and other mechanisms that enable consumers to exercise choices about behavioral tracking, see the “Services From Other Parties/Internet-Based Advertising” section below.

Please note that if you block certain cookies from the website, it may not function as intended.

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. For more information, visit www.allaboutdnt.org.

Information Provided by Other Sources

We may receive Personal Information about you from our Service Providers, including inventory, technical or billing vendors; data analytics and internet providers; other third-party sources, and other commercially available sources.

II. How We Use  Your Information

We use your Personal Information for our business purposes, including to provide and improve our website and provide Services, to respond to your inquiries and requests, to prevent fraud and other criminal activity, for marketing purposes, and for other purposes for which we may notify you. For example, we may use your Personal Information for the following and other purposes as permitted or required by law:

· Administration of customer relationships. We use identifiers, contact information, and other Service-related information to administer our relationship with our customers, including to enable you to participate in interactive features of our Services, to provide customer support, to fulfil orders and customer transactions, updating customer records, and addressing customer inquiries or feedback.

· Sending relevant marketing/informational messages. We use identification data, contact information, Device, Internet and Network Activity Information, and mailing list information to communicate with you by way of email messages to provide you with news, special offers, and general information about other services and events which we offer unless you have opted not to receive such information.

· Improving our website. We use information derived from Device, Internet, and Network Activity to improve the content, functionality, and user-friendliness of our website.

· Keeping our websites and IT systems and processes safe. We use identification data, contact details, and Device, Internet, and Network Activity information, to ensure the security and confidentiality of our website, network, and your data, as well as to prevent illegal activities, including fraud, which could harm you and us.

· Complying with legal requirements – We use identification data, contact details, and financial information to comply with legal and regulatory requirements, including for know your customer, anti-money laundering or fraud detection purposes, other industry-specific regulatory requirements and fulfillment of our ethical obligations. This processing is necessary for the purpose of complying with legal requirements that apply to us.

III. Disclosure of Your Information

We do not sell, share, or otherwise disclose the Personal Information we have collected about you through our Services to third parties unless otherwise stated in this Policy or with your consent. We may disclose your Personal Information to the following categories of recipients:

· With our Service Providers who we utilize to provide or facilitate our Services. A Service Provider is an entity that performs functions on our behalf, and processes Personal Information on our behalf in connection with performing those functions. For example, we may disclose information to Service Providers that help us maintain our website and systems we use to administer our Services;

· With Ajax Turner Company, Inc., our business partners, subsidiaries, business units, and other affiliates for legitimate business purposes;

· We may disclose and transfer Personal Information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, demerger, corporate division, or divisive reorganization, dissolution, bankruptcy, or other change of ownership or control (whether in whole or in part);

· As we believe to be necessary and appropriate. We may also disclose Personal Information: (i) as permitted by law; (ii) if we determine that the disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency or other legal process; (iii) to protect the legitimate rights, privacy, property, interests or safety of our company or our affiliated entities’ customers, business partners, employees or the general public; (iv) to pursue available remedies or limit damages; (v) to enforce our Terms of Use; and (vi) to respond to an emergency; and

· With other parties when we have your consent to do so.

IV. Data Security and Retention

The security of your data is important to us, but please remember that no method of transmission over the internet or electronic storage is secure or error free. While we strive to use commercially acceptable means to protect your Personal Information from loss, misuse, and unauthorized access, alteration, disclosure, and destruction, we cannot guarantee its absolute security. By using our Services, you acknowledge that there are data security and privacy limitations inherent to the use of the internet, and that the security, integrity, and privacy of any and all information exchanged between you and Ajax Turner cannot be guaranteed. We cannot ensure or warrant the security of any information you transmit to us or that we store, and you do so at your own risk.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. The criteria used to determine the applicable retention period for your information includes the length of time we have an ongoing relationship with you and provide Services to you, and whether there is a legal obligation to which we are subject that requires us to retain your information.

V. Services from Other Parties; Internet-Based Advertising

Please note that this Privacy Policy does not apply to the practices of third parties on their own websites, including our Service Providers, marketing Service Providers, or other third parties, such as Provi and Vermont Information Processing (VIP). When you access a third party’s website through links on our website, information collected from you on those third-party websites is governed by their privacy policies. We are not responsible for and do not control the security or privacy of your information when you visit those websites. We encourage you to read the privacy policy of every website you visit.

For example, we and certain third-party partners may place advertisements for our Services on websites, apps, and platforms operated by others. If you would prefer not to receive certain interest-based advertising, you can opt-out of this activity at the Digital Advertising Alliance (DAA) website at optout.aboutads.info, optout.networkadvertising.org, optout.privacyrights.info, and www.aboutads.info/appchoices.

If you do not want the Services to collect information through the use of cookies, you can also set your web browser to reject cookies from the Services. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. Please note that this sort of opt-out may be browser and/or device specific. Please also note even if you choose to remove your information or opt-out, you may still see advertisements while browsing online. However, the advertisements may be less relevant to you and your interests.

VI. Changes to this Policy

The Effective Date of this Privacy Policy is set forth at the top of this webpage. As business needs change, we may amend this Privacy Policy. The amended Privacy Policy supersedes all previous versions. If we update this Privacy Policy, we will notify you by posting a new Privacy Policy on this page. If we make any material changes to this Privacy Policy, we will notify you as required by law, which may include by email to the email address you provided to us, if available. We encourage you periodically to check this page for updates.

VII. Contact Us

We welcome your questions and comments about this Privacy Policy or how we process your Personal Information. Please contact us using the information below, and we will respond to you as soon as reasonably possible.

4010 Centrepointe Dr

La Vergne, TN 37086

Info@ajaxturner.com

(615) 501-9900