Privacy Policy

PLEASE READ THE FOLLOWING TERMS AND CONDITIONS RELATING TO YOUR USE OF THIS SITE CAREFULLY.

TPN Holdings LLC respects your privacy. We are committed to safeguarding your privacy and protecting your information against unauthorized use.

Who Processes your Personal Information
This privacy policy (“Policy”) applies to the processing of personal information by TPN Holdings LLC.

European Union and the UK

Please note that separate policies apply to the processing of personal data by our TPN Holdings LLC branded companies in the European Union (EU) and the UK and other jurisdictions where our companies operate.

California

If you are a California consumer and would like information about our online and offline privacy practices and your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement.”

Purpose of this Policy

This Policy explains our approach to any personal information that we might collect from you using this website (the “Site”) and any personal information about you we might collect/process in other situations or interactions with us, and the purposes for which we process your personal information. This Policy will inform you of the nature of the personal information about you that is processed by us and how you can exercise your rights. This Policy is intended to assist you in making informed decisions when using the Site or otherwise providing personal information to us or in other situations where we may process your personal information.

UNLESS PROHIBITED BY LAW, BY USING OR ACCESSING THE SITE, YOU SIGNIFY YOUR AGREEMENT TO BE BOUND BY OUR PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE.

Type of Personal Information We Collect/Process

When we talk about personal information, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, an online identifier (such as an IP address) or to other factors that are specific to them. Categories of personal information we may collect when you choose to provide it include:

contact information (e.g. name, physical address, telephone number, email address);
your date of birth;
information about your employment or education history;
information for hiring talent and human resources (e.g. work eligibility status, financial account
information, government-issued identification information or dietary requirements);
your image;
your online identifier (e.g. cookie ID); or
any additional data that may identify you which you submit to us.
For more information about the personal information we collect please refer to section HOW WE USE PERSONAL INFORMATION below and the COOKIES section.

Personal Information of Children

We do not intend to or knowingly collect personal information from children under the age of 16.

Ways of Obtaining Personal Information

We may collect and receive your personal information using different methods:

Personal information you provide to us. You may give us your personal information directly. This will be the case when, for example, you contact us with enquiries, complete forms on our Site or in hard copy, subscribe to receive our marketing communications or provide feedback to us, provide services to us or otherwise through your interactions with us.
Personal information we collect from you automatically. When you access and use our Site, we will automatically collect certain technical information about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar tracking technologies (see COOKIES section below.).
Personal information received from third parties. From time to time, we may receive personal information about you from third parties. For example, we may receive your contact details from an industry contact or our client, or we may receive your CV or resume from your agent or recruitment service provider. We may also use third parties to collect personal information about your interactions with our Site.

How We Use Personal Information
Our primary goal in collecting personal information from you is to:

verify your identity,
provide our services to clients;
help us improve our Site, products and services and develop and market new products and
services;
carry out requests made by you to us;
investigate or settle inquiries or disputes;
comply with any applicable law, court order, other judicial process, or the requirements of
a regulator;
enforce our agreements with you;
protect the rights, property or safety of us or third parties, including our other clients and
users of the Site;
provide support for the provision of our services;
carry out recruitment activities; and
use as otherwise required or permitted by law.

We set out in more detail the specific ways in which we may use your personal information below. Please note that these examples are non-exhaustive and may be subject to local rules and restrictions – we will only carry out these activities to the extent permitted by local law. If local law requires us to obtain consent in order to process the data as described then we will do so.

Client information.
We may collect personal information about our client and potential client contacts to enable us to respond to client requests, to administer client accounts with us, to conduct credit checks (if permitted by applicable law), and to verify and carry out financial transactions for payments made to us.
Who do we share personal information with for this purpose? We may share such personal information with our third party vendors (such as our payment service providers or IT providers), financial institutions, group companies, affiliates, professional advisors, regulatory bodies or other law enforcers or such other third parties as indicated in SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Insight and analysis.
We may analyse individuals’ contact details with other personal information that we observe about them from their interactions with our Site, our email communications and/or with our services. We may use cookies, log files and other tracking technologies to collect personal information from the computer hardware and software used to access the Sites, or from mobile devices. This may include the following:

an IP address to monitor Site traffic and volume;
a session ID to track usage statistics on our Sites; and
information regarding your personal or professional interests, demographics, experiences with our services and contact preferences.

Our web pages and emails may contain cookies, web beacons and pixel tags (“Tags”). Tags allow us to count users who have visited a web page or opened an email and collect other types of aggregated information. Once a recipient clicks on an email that contains a Tag, their contact information may subsequently be cross-referenced to the source email and/or the relevant Tag. In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Please see our COOKIE POLICY available on the Site for further information. This information is used to create insights about our visitors’ browsing habits on our Site. By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see.

Receipt of services.
If we have engaged an organization to provide us or our clients with products or services (for example, IT support or financial advice), we will collect and process your personal information if you are a contact within the relevant organization in order to manage our relationship or that of our clients with the organization, to receive products and services from the organization and, where relevant, to provide our services to others including our clients.

Who do we share personal information with for this purpose?
We may share such personal information with our clients, group companies, affiliates, partners, agents, third party vendors or professional advisers or such other third parties as indicated in SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Recruitment.
If individuals apply for a job with us or otherwise express an interest in working for us, we will collect contact details and CV or resume information from the individual. We use such personal information to:

assess the individual’s suitability for any position for which they applied (or future positions for which we think the individual may be suitable) including employment or freelance positions, summer placements or internships and also any business support or services role whether such application has been received by us online, via email or by hard copy or in person application;
to take any steps necessary to enter into any contract of employment (or otherwise) with
the individual;
to comply with any regulatory or legal obligations in relation to any such application; and
to review our equal opportunity profile in accordance with applicable legislation. We do
not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual
orientation, disability or any other basis covered by local legislation.

Who do we share your personal information with for this purpose?
We may share such personal information with our group companies, affiliates, third party vendors or professional advisers or such other third parties as indicated in SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Visiting our premises.
If an individual visits any of our premises we may collect contact information as part of our sign in process. We may also capture their image on our surveillance camera or CCTV.

Who do we share personal information with for this purpose?
We may share such personal information with our clients, group companies, affiliates, recruitment partners or agents, third party vendors (such as our IT providers) or advisers or law enforcers or such other third parties as indicated in SHARING YOUR PERSONAL INFORMATION below in connection with this purpose

Business administration and legal compliance.
We may use an individual’s personal information for the following business administration and legal compliance purposes:

to facilitate the operation or effective management of our group of businesses;
to comply with our legal obligations (including regarding information security);
to enforce or protect our legal rights;
to deal with complaints;
to protect the rights of third parties (including where health or security of an individual is endangered (e.g. a fire)); and
in connection with a business transition or sale such as a merger, re-organization, acquisition by another company, or sale of all or a portion of our assets.

Who do we share personal information with for this purpose?
We may share personal information with our clients, group companies, affiliates, agents, partners, third party vendors or professional advisers, emergency service providers or law enforcers or other regulatory bodies (including tax and social security authorities) or such other third parties as indicated in SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Sharing Your Personal Information
We may share your personal information with any of our group affiliates, or with our agents or partners clients, contractors (for example who we engage on specific client projects), services providers (for example who provide us with IT systems or support), professional advisors (such as our lawyers) or government or regulatory bodies. Your data may be shared for the following purposes.

to provide our services to clients or otherwise receive assistance in processing transactions;
fulfilment of requests for information, receiving and sending communications, updating
marketing lists, analysing data;
provision of IT and other support services;
to facilitate the operation and effective management of our group of businesses;
to comply with a legal obligation or in connection with a legal claim or dispute or to otherwise
protect our legal rights; and
assistance in other ancillary to the operation of tasks, from time to time.
Our agents, partners and contractors will use your personal information to the extent necessary to perform their functions. For more details about how we may share your personal information in connection with a particular use case, please refer to the relevant use case above. Please note that these third parties may be located in other jurisdictions.

Please note, the types of third parties we share your personal information with set out above is non- exhaustive and there may be circumstances where we need to share personal information with other third parties in order to operate our Site and to provide our services. We will notify you of any other circumstances where we would share your information on a case by case basis.

Obtaining Your Consent
Where our use of your personal information requires your consent, you can provide such consent: § at the time that we collect your personal information following the instructions provided; or § by informing us by e-mail, post or phone using the contact details set out in this Policy
Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.

Your consent is provided on a voluntary basis. However, if you do not provide us with your personal information, we may not be able to process your applications, handle your requests, respond to your inquiries or provide you with our services.

Security and Confidentiality of your Personal Information
We are committed to keeping the personal information you provide to us secure. We take reasonable and appropriate measures to protect your personal information, including but not limited to sophisticated software and hardware that prevent personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

Information regarding job applications is encrypted and transmitted in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the URL. Only employees or third parties who need the information to process a specific request are granted access to personally identifiable information.

Access
To the extent required by applicable law, we will provide you with reasonable access to the personal information maintained about you and a reasonable opportunity to correct, amend or delete the information where it is inaccurate or has been processed erroneously, as appropriate. We may limit or deny access to personal information where permitted by law (such as where the burden or expense of providing access would be disproportionate or where the rights of third parties would be violated). You may exercise these rights verbally or in writing by using our contact information provided in the section below entitled CONTACT DETAILS. We will endeavor to promptly respond to your requests and will respect time frames set by local legislation where applicable.

Please note that in order for you to assert these rights we may need to verify your identity to confirm your right to access your personal information. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal information from you than we currently have.

Choice and Means

We generally offer you the opportunity to choose whether your personal information may be disclosed to third-party controllers or used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by you. Unless we offer you an appropriate choice, we use personal information only for purposes that are materially the same as those indicated in this Policy. To exercise your choices you may contact us as indicated in this Policy.

We may share personal information with our affiliates and subsidiaries as described under SHARING YOUR PERSONAL INFORMATION. We may disclose personal information without offering an opportunity to opt out, and we may be required to disclose such information (a) to third-party processors we have retained to perform services on our behalf and pursuant to our instructions, (b) if we are required to do so by law or legal process, or (c) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements, and in other situations described in that section.

Opt-Out and Unwanted Communications

To opt-out of any future promotional or marketing communications or any other commercial communications from us, you should send a request to us at the contact information in the section entitled CONTACT DETAILS. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of this Site may no longer be available to you.

Enforcement Rights and Mechanisms

We will ensure that this Policy is observed and duly implemented. If at any time you believe that your personal information has been processed in violation of this Policy, or if you have any inquiries or complaints about the use or limitation of use of your personal information, you may contact the relevant individuals in CONTACT DETAILS section.

Third Party Links and Services

This Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Policy no longer applies to these third-party websites and third-party service providers unless we process your data jointly with such third parties.

Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.

This Site may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

Cookies

We use cookies and similar technologies to collect personal information from the computer or other device you use to access the Site. “Cookies” are pieces of information that may be placed on your device for the purpose of collecting data to facilitate and enhance your communication and interaction with our Site. We may also allow certain third parties to place cookies as described below.
We use cookies and other technologies on all our sites to ensure the best possible experience on our Site. These uses include:

analytical cookies to recognize and count users of our Site, measure the effectiveness of our content, and understand how visitors use our Site. We currently use Google Analytics for this purpose; or
placing, or allowing a third party to place, functional cookies to make a website easier to use, such as cookies that maintain a user’s session.

You can review your Internet browser settings to exercise choices you have for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you may be required to re-enter your log-in details. For more information about how we use cookies please see our COOKIE POLICY below.

How Long Do We Keep Your Personal Information?

Where applicable law imposes restrictions on the length of time for which personal information can be retained, we will generally comply with this by retaining personal information only for as long as is necessary for the purposes described in this Policy, after which it will be deleted from our systems. The principle may be departed from where required by law.

If any personal information is only useful for a short period (e.g. for a specific activity or in relation to recruitment), we may delete it at the end of that period. Please note that if you are an unsuccessful candidate we may keep your information for a short period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information on a suppression list so that we know not to send you further marketing communications in the future

Onward Transfers

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected, including the U.S. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described in this Online Privacy Notice and will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries other than the one in which you provided the information.

Compliance with the Privacy Shield

TPN Holdings LLC complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. TPN Holdings LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please

visit https://www.privacyshield.gov/. TPN Holdings LLC no longer relies on the EU-U.S. Privacy Shield to transfer personal information to the U.S.

Modifications to this Policy

We reserve the right to modify this Policy as needed, for example, to comply with changes in laws, regulations or requirements introduced by applicable data protection authorities. Changes must be approved by our privacy points of contact, the office of the corporate legal department, or their designees who will seek input as they reasonably deem appropriate from corporate executives for the amended Policy to enter into force. If we make changes to the Policy, this amended Policy will be submitted for renewed approval according to the relevant applicable provisions of the law. We will post all changes to the Policy on relevant internal and external websites.

We encourage you to review this Policy periodically to be informed of how we use your personal information.

Contact Details

For questions or concerns about this Policy, or to ask questions or express concerns about our collection, management and processing of personal information, or to exercise your rights, you may contact our Privacy Officer at privacy@tpnretail.com

Or at our corporate headquarters:

7850 N. Beltline Rd
Irving, TX 75063

Recourse Enforcement and Liability

We are subject to the investigatory and enforcement powers of the Federal Trade Commission. We have mechanisms in place designed to effect compliance with the Privacy Shield Principles. We conduct an annual self-assessment of personal information handling practices to verify that the attestations and assertions we make about our Privacy Shield privacy practices are true and that such privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

Recourse: You may file a complaint concerning our processing of your personal information. We will take steps to remedy issues arising out of any alleged failure to comply with the Privacy Shield Principles. You may contact us as specified below about complaints regarding our personal information handling practices.

Alternative Dispute Resolution

If your complaint cannot be resolved through our internal processes, we will cooperate with the alternative dispute resolution provider JAMS (Judicial Arbitration and Mediation Services) pursuant to the JAMS International Mediation Rules, available on the JAMS website at: www.jamsadr.com/international-mediation-rules.

JAMS mediation may be commenced as provided for in the relevant JAMS rules. The mediator may propose any appropriate remedy, such as deletion of the relevant personal information, publicity for findings of noncompliance, payment of compensation for losses incurred as a result of noncompliance, or cessation of processing of the personal information of the individual who brought the complaint. The mediator or the individual also may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over us. Under certain circumstances, individuals also may be able to invoke binding arbitration to address complaints about our compliance with the Privacy Shield Principles.

In addition to the above and under certain conditions, the individual may invoke binding arbitration for complaints that have not been resolved by any of the other Privacy Shield mechanisms. See Annex 1of the Privacy Shield framework for further
information: https://www.privacyshield.gov/servlet/servlet.FileDownload?file=015t00000004qAg

California Consumer Privacy Statement

This California Consumer Privacy Statement supplements this Policy and applies solely to California consumers. This section provides information about our online and offline privacy practices. This Statement does not apply to our personnel.

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you.

Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, and other similar identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80: such as signature, physical characteristics or description, education, financial information
Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
Commercial Information: commercial information, such as records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
GeolocationData
Sensory Information: audio, electronic, visual, and similar information
Employment Information: professional or employment-related information
Education Information: education information that is not publicly available personally identifiable
information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
Inferences: inferences drawn from any of the information identified above to create a profile
about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

We may use the categories of personal information listed above for the purposes described in this Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

Purposes

Categories of Personal Information

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Geolocation Data; Employment Information; Education Information and Inferences

Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

Debugging to identify and repair errors that impair existing intended functionality

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Geolocation Data; Employment Information; Education Information and Inferences

Undertaking internal research for technological development and demonstration

Undertaking activities to verify or maintain the quality or safety of a service and to improve, upgrade, or enhance the service

In addition, we may also use the following categories of personal information for purposes of managing our career opportunities: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Sensory Information; Employment Information; Education Information and Inferences

Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.

a. Sources of Personal Information
We may have obtained personal information about you from various sources, as described below:

Categories of Sources of Data Collection

From your devices, such as when you visit our Site

Our affiliates and subsidiaries

Categories of Personal Information

Directly from you, such as when you contact us with a question or comment

Our Clients

Vendors who provide services on our behalf

Social networks

Online advertising companies

Government entities

Consumer data resellers

b. Sharing of Personal Information
We may have shared your personal information with certain categories of third parties, as described below:

Categories of Third Parties

Categories of Personal Information

Our affiliates and subsidiaries

Our clients

Vendors who provide services on our behalf

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity;

Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Professional services organizations, such as auditors and law firms

Our joint marketing partners

Our business partners

Advertising networks

Internet service providers

Data analytics providers

Government entities

Operating systems and platforms

c. Sale of Personal Information
We do not sell, and have not sold in the previous 12 months, consumers’ personal information.

d. Disclosure of Personal Information for a Business Purpose
We may have disclosed to third parties the following categories of personal information for a business purpose: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences.

California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.

Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.

How to Submit a Request:
To submit an access or deletion request, call us at 1-214-692-1522.
To submit a Shine the Light request, email us a privacy@tpnretail.com.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide us with information about you to verify your identity. The type of information that we ask for may vary depending on the type and sensitivity of the personal information we hold about you or that you request. If additional information is required to verify your request, we may contact you to provide us with that information before responding to your request for access or deletion. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact privacy@tpnretail.com to request this Statement in an alternative format.

Last updated 04/28/2021