Privacy Policy

This Privacy Policy applies to and describes the treatment of Personal Information (“Personal Information”) collected through this website and any other websites or applications that post a link to this Privacy Policy (each a “Site”); certain offline collection of Personal Information through the Services; and from certain third party sources, as described in more detail below.

Participation in the Site and Services is completely voluntary. You are not required to provide all Personal Information identified in this Privacy Policy; however, be advised that if you choose not to provide certain Personal Information, we may be unable to provide some or all of the Services to you, and your ability to use the Site or Services may be limited. Please be sure to review the Site’s Terms of Use which, in addition to this Privacy Policy, governs your use of the Site. If you voluntarily provide Personal Information in the course of using our Site or Services, you consent to our Privacy Policy and Terms of Use.

Please note, unless otherwise stated, this Privacy Policy does not apply to the following:

• Any Sites or Services that post separate privacy policies or privacy notices.

• Personal Information of job applicants or current or past employees, which is governed by a separate privacy policy.

• Personal Information we collect on behalf of our Clients (as described below).

• Information that is de-identified, aggregated, or anonymous (“Anonymized Data”).

• Third party websites, applications or services (collectively, “Third-Party Sites”), even if they are accessible from our Site or Service.  Any information collected on Third-Party Sites is governed by that Third-Party Site’s privacy policy, and we are not responsible for the privacy practices of those Third-Party Sites. We encourage you to be aware when you leave our Site and to read the privacy policies of such Third-Party Sites to understand their privacy practices. Please also keep in mind that privacy choices you make on Third-Party Sites may not apply to our use of your Personal Information.

We are a leading sales agency and innovative business solutions provider in the military resale channel, growing business for our brand clients and retailer customers (our “Clients”), while supporting our service members, their families, and mission readiness. With roots in the military resale industry dating back decades, we deploy a dedicated team to every commissary and exchange in the United States and abroad, offering the full spectrum of headquarter sales services, business processing support, analytics and insights, and retail services.  As such, we primarily provide business-to-business services and do not generally provide services directly to consumers.

While providing Services to our Clients, we may collect Personal Information related to our Client’s consumers on their behalf. The collection and use of this information on behalf of our Clients is governed by our contract with the applicable Client and the Client’s own privacy policies, not this Privacy Policy. We are not responsible for the privacy policies or practices of Clients or other third parties.

We may collect the following categories of Personal Information through the Site and Services:

• Your contact information, such as your first and last name, phone number, email address, and postal address, and that of others you provide to us (e.g., other contacts in your business);

• Biographical or demographic information, such as your date of birth, age, gender, employer and job title/position;

• Commercial information, such as Services you have purchased or considered purchasing from us;

• Activity information about your use of our Sites and Services, such as your preferences and how often you use the Site or Services;

• Usage, technical and device information when you visit our Sites or open emails we send, including browser or device information, unique device identifier, URL that referred you to our Site or Services, and IP address. We may collect your location information derived from this information or from beacon technologies (as described below), where permitted by law to do so;  

• Information you submit through any “Contact Us” feature, or otherwise provided to us in your communications with us.

We may also collect, or create from your Personal Information, Anonymized Data. Our use of Anonymized Data is not subject to this Privacy Policy.

We may obtain Personal Information from the following categories of sources:

Directly from You

We collect Personal Information you provide to us when you request or purchase Services or information from us, sign up for our mailing or email marketing lists (where applicable), participate in a survey, contact us, or otherwise interact with our Site and Services.

Your Use of the Site and Services

We and our service providers may collect information using analytics tools when you use our Sites and Services, that store or collect information about your interactions with our Sites and Services.

Cookies and Other Tracking Technologies

We may use various methods and technologies to store or collect information (referred to herein as “Tracking Technologies”), including when you visit or use our Sites. These Tracking Technologies may include the following:

• Cookies. A cookie is a file placed on a device to uniquely identify your browser or to store information on your device. Our Sites may use HTTP cookies, HTML5 cookies, Flash cookies, and other types of cookie technology.

• Web Beacons/Pixels. A web beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages or emails we send.

• ETags. An eTag or entity tag is a feature of a browser cache. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.

There may be other Tracking Technologies used by us now or later developed and used by us in connection with our Sites and Services. Sites linking to this Privacy Policy utilize different Tracking Technologies, and each such Site has its own Cookie Policy. For more information and your choices and options with respect to our use of Tracking Technologies, please visit the relevant Website Cookie Policy. Please note that changes you make to settings for Tracking Technologies may render certain functions of our Sites or Services inoperable or more difficult to use.

Third Parties

We may obtain Personal Information from third-party sources, such as our Clients in connection with our Services; service providers or vendors who help us update or supplement information previously collected about you, such as vendors we use to validate postal or email addresses; our affiliates and subsidiaries; lead generation partners; and other trusted partners. In addition, there may be cases where our Sites or Services include functionality that allows interaction between the Site or Services and a third party website or application, which may involve that third party providing information to us (for example, the ability to send an email or post on social media through our Sites or Services). In these cases, the third parties may retain your Personal Information, and these third parties’ data practices are not subject to this Privacy Policy. We encourage you to review applicable third-party privacy policies before using any third-party tools integrated into our Sites or Services.

We may use your Personal Information to:

• Provide you with requested Services;

• Operate, understand, optimize, develop, or improve our Sites, Services and operations, including tailoring the Sites and Services to your preferences;

• Establish and verify the identity of visitors to our Sites or users of our Services;

• Open, maintain and administer accounts you open through our Sites or Services;

• Send you email marketing messages, where you have signed up to receive them;

• Respond to your questions, inquiries, comments, complaints, or other communications you send to us;

• Communicate with you about our Sites and Services, including important updates to Sites and Services;

• Provide you with information about new opportunities, and related communications;

• Ensure our compliance with relevant legal and regulatory obligations;

• Maintain the security and integrity of our systems, Sites and Services; and

• Detect, investigate and prevent activities that may violate our policies or be illegal.

We do not share your Personal Information that we collected directly from you with third parties for their direct marketing purposes unless we have first given you the choice to consent or withhold consent to such sharing. We may share your Personal Information in the following circumstances, or as otherwise described in any privacy notices provided to you at the time your Personal Information was collected:

• When you request that we share your Personal Information with other companies so they can send you information, offers and/or promotions about their products and services, or when you interact with third parties through our Sites or Services, such as social media sites. Please note we are not responsible for the privacy practices of these third parties, and we encourage you to review their privacy policies and practices before requesting information from or otherwise interacting with them;

• When we use third-party service providers to perform services on our behalf, such as hosting and analytics providers, consulting services, auditors, and other providers; however, these companies are prohibited from using your Personal Information for purposes other than those requested by us or required by law;

• With our affiliate companies, meaning companies that are subsidiaries, joint ventures, or are otherwise controlled by or under common control with us; and

• In connection with the sale of one of our businesses, to enforce our Terms of Use or policies, to ensure the safety and security of visitors to our Sites and users of our Services,  to protect our rights and property and the rights and property of others, to comply with legal processes, and in other cases if we believe in good faith that disclosure is required by law.

Individuals in certainjurisdictions may have certain rights under applicable privacy laws. Rightsspecific to residents of California, Nevada, the United Kingdom, and theEuropean Economic Area are described below. Subject to applicable law, you mayhave the right to request access to, modification or correction of, or deletionof your Personal Information, and information on how it has been used ordisclosed. For example, if you are a resident of Canada, you may be able torequest access to and/or correction of your Personal Information. To exerciseyour rights, you may contact us at [email protected]. We willrespond as soon as practicable, and in accordance with applicable law. We maytake steps to verify your identity prior to responding to your request, and, wherepermissible by law, we may charge for such submissions.

If you would like to stopreceiving newsletters or other marketing or promotional messages, notificationsor updates from us, you may do so by following the unsubscribe instructionsthat appear in those communications, or by contacting us [email protected] to opt-out of marketing emails. Please beadvised that you may not be able to opt-out of receiving certain service ortransactional messages from us, including legal notices.

Nevada Residents

We do not exchange Nevada residents’ PersonalInformation for money with anyone so they may further license or sell thePersonal Information to additional parties.

This section applies only to California residents, as defined in the California Consumer Privacy Act (“CCPA”). As a reminder, this Privacy Policy does not apply to the data practices of third parties, including our Clients. If we collected information on a Client’s behalf, the relevant Client’s privacy policy governs the collection and use of that information.

Your Rights Under California Law

If you are a California resident, subject to applicable law, you have the following rights with respect to your Personal Information:

• Right to Know. You have the right to request, up to two times each year, the categories and/or specific pieces of Personal Information about you that we collect, use, disclose and sell, as applicable, and subject to applicable legal exceptions.

• Right to Delete. You have the right to request that we delete Personal Information that we collect from you, subject to applicable legal exceptions.

• Right to Non-discrimination. You have the right not to receive discriminatory treatment by us for the exercise of your rights under the CCPA.

• Right to Opt Out of “Sale”. You have the right to opt out of the “sale” of your Personal Information to “third parties,” as those terms are defined in the CCPA. As it relates to the Sites and Services to which this Privacy Policy applies, we do not “sell” your Personal Information without your consent.

California residents also have the right under the Shine the Light Act to request and receive certain information about the disclosure of Personal Information to third parties for their own direct marketing use, and options with respect to such disclosures. Because we, as it relates to the Sites and Services to which this Privacy Policy applies, do not share your Personal Information with third parties for their direct marketing use without your consent, these requirements are not applicable.

How to Exercise Your California Rights

You can submit a Right to Know or Right to Delete request through our PRIVACY PORTAL (click the link to access) or by calling us, toll free, at 1-888-651-2032.

These rights are subject to our being able to reasonably verify your identity. We will verify your identity by matching information you provide with your request with information in our systems; and, for requests submitted through our Privacy Portal, by additionally requiring you to respond to an automated email to verify your email address. In general, we will ask you to provide the following information in connection with your request: first and last name, email address, state and country of residence, and the nature of your relationship with Advantage. We may also request additional documentation or information solely for the purpose of verifying your identity.

You may also authorize someone else to exercise these rights on your behalf. When a third party submits a request on your behalf, they must indicate in our Privacy Portal or on the phone that they are an authorized agent, and supply us with evidence of such authorization; we will not fulfill any request submitted by a third party related to your Personal Information until we have received confirmation that you authorized such third party to submit a request on your behalf.

Please note that your exercise of these rights is subject to certain exemptions and exclusions, and your requests may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we reject any part of your request and the reason(s) we are unable to honor it.

CCPA Disclosures

In addition to the information provided elsewhere in this Privacy Policy, we make the following disclosures to comply with the CCPA:

• We collected the following categories of Personal Information in the last 12 months: identifiers/contact information; biographical/demographic information (such as age and gender); commercial information; Internet or other electronic network activity information; professional or employment-related information; geolocation data (in some cases); and inferences drawn from the above.

• The sources of Personal Information we collected are outlined in the How We Collect Your Information section above.

• The business or commercial purposes of collecting Personal Information are outlined in the Why We Collect Your Information section above.

• We disclosed the following categories of Personal Information for a business purpose in the last 12 months: identifiers/contact information; commercial information; and Internet or other electronic network activity information. We disclose these categories only as described in the How We Share Your Information section above.

• We do not “sell” Personal Information of known minors under 16 years of age.

Our Site and Services are operated in the United States. If you are located outside of the United States, please be advised that information we collect, including Personal Information, may be transferred to, and processed, stored and used, in the United States, and that this is necessary to provide you with the information or Services you have requested, and/or perform any requested transactions. Privacy laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States subject to applicable law. By using this Site or the Services, or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.  For more information about our policies regarding cross-border transfers of Personal Information, you may contact us at [email protected].

Visitors from the United Kingdom and European Economic Area

This section applies only to the extent you are a resident of the United Kingdom (“UK”) or European Economic Area (“EEA”). We are the data controller of your Personal Information that we collect through our Site and Services, except where we collect your Personal Information as a data processor on behalf of a Client. In that case, the collection and processing of your Personal Information is governed by the relevant Client’s privacy notice.

We process your Personal Information under the following legal bases:

• Our Legal Obligations. We may need to process your Personal Information to comply with relevant laws and regulatory requirements, or to respond to lawful requests, court orders, and legal processes.
• Your Prior Consent. We rely on your consent for certain processing, such as the placement of cookies on your device or sending you marketing communications. You can withdraw your consent at any time.
• To Perform a Contract. We will process your Personal Information in connection with your requests or any contracts which you enter with us.
• Our Legitimate Interests. Weprocess Personal Information:
  - To facilitate communication between you and us,or carry out actions you request;
  - For the security and safety of the Site,technology connected to the Site, and visitors to the Site;
  - To detect and prevent fraud;
  - To protect and defend our rights and property orthat of others; and 
  - To manage and administer the Site and Services.

The following rights are provided to residents of the UK and EEA under the General Data Protection Regulation (“GDPR”) or equivalent local laws:

• Right to Know. You have the right to request what Personal Information we collect and process.
• Right to Access. You have the right to request access to, or copies of, the Personal Information we process in a portable format.
• Right to Delete. You have the right to request the deletion of your Personal Information, subject to legal and other obligations.
• Right to Correction. You have the right to request corrections to any inaccuracies in your Personal Information.
• Right to Object. You have the right to object, with legitimate grounds, to the processing of your Personal Information, subject to legal and other obligations.
• Right to Restrict Processing. You have the right to request we restrict the processing of your Personal Information in certain situations.
• Right to Lodge a Complaint: You have the right to file a complaint with your applicable data protection authority, which can be located here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

If you are a resident of the UK or EEA and wish to exercise any of these rights, you may do so by using our PRIVACY PORTAL (click the link to access).

We recognize the importance of children’s safety and privacy. Our Sites are general audience websites and applications and are not designed or intended to attract or be used by children under the age of 16. We do not knowingly collect or request Personal Information from children under the age of 16. If you are under the age of 16, you are not permitted to use this Site and should not send us any information about yourself. In the event we become aware we have collected Personal Information from a child under the age of 16, we will take steps to dispose of that information in accordance with the Children’s Online Privacy Protection Act and other applicable laws and regulations. If you are a parent or guardian and you believe your child under the age of 16 provided us with Personal Information without your consent, you may contact us at [email protected].

The security, integrity and confidentiality of your Personal Information are extremely important to us. We have implemented technical and organizational safeguards designed to help protect and secure your Personal Information. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable; and no data transmission over the Internet is guaranteed to be secure. As a result, we cannot guarantee or warranty the security of any Personal Information you provide to or from our Site or through our Services. We will retain your Personal Information for the length of time needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

We may update this Privacy Policyfrom time to time. The version date of this Privacy Policy is located at thetop of the page. We encourage you to review this Privacy Policy often to remaininformed of how we use your Personal Information.

For more information about our privacy practices, or if you have a comment or question about this Privacy Policy, you can contact us by email at [email protected].

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