Privacy Policy

1. Introduction

PLEASE READ THIS PRIVACY POLICY ("POLICY") CAREFULLY TO UNDERSTAND HOW WE COLLECT, USE, AND TREAT YOUR PERSONAL INFORMATION THROUGH THE USE OF OUR WEBSITES, MOBILE APPLICATIONS, AND THROUGH EMAIL, TEXT, AND OTHER ELECTRONIC COMMUNICATIONS BETWEEN YOU AND PT INTERMEDIATE HOLDINGS IV, LLC, AS WELL AS YOUR CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE WEBSITES, APPLICATIONS, OR COMMUNICATE THROUGH EMAIL, TEXT, OR OTHER ELECTRONIC COMMUNICATIONS.

PT Intermediate Holdings IV, LLC and its affiliates and subsidiaries (including the PT Intermediate Holdings IV, LLC subsidiaries in the USA and in Canada) (collectively, "Encompass Supply Chain Solutions," "Appliance Parts," "Eldis Group" or also referred to herein as the "Company" or "we") is committed to protecting the privacy and security of the information we collect, use, share, and otherwise process as part of our business. We respect your privacy and are committed to protecting it through our compliance with this policy. We also believe in transparency, and are committed to informing you about how we treat the information we collect and process.

This Policy describes the types of information we may collect from you or that you may provide when you visit top-level domain websites (each, a "Website", collectively the "Websites"), or as otherwise set forth herein, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect:

• on our Websites;
• through mobile applications you download from application stores (like Google Play® and the Apple App Store®) which provide dedicated non-browser-based interaction between you and our Websites ("Apps");
• in email, text, and other electronic messages between you and our Websites ("Messaging"); and
• when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

This Policy does not apply to information collected by:

• The Company offline or through any other means, including on any other website operated by the Company or any third-party; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites, Apps, or Messaging modalities. By accessing or using these Websites, Apps, or Messaging modalities you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of these Websites, Apps, and Messaging modalities after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

Privacy Principles

When processing personal information, the Company will follow these principles in compliance with applicable law including, but not limited to, the EU General Data Protection Regulation 2016/79 ("GDPR"), the Canadian Personal Information Protection and Electronic Documents Act ("PIPEDA"), the CCPA, CPRA, and State Privacy Laws (as those terms are more fully defined in this Policy, and other applicable data privacy and security laws:

• The Company endeavors to inform persons whose Personal Information the Company collects, in accordance with applicable law, when those persons are first asked to provide personal information to the Company, or as soon as practicable thereafter. This includes, as more fully set forth in this Policy, providing information about (i) the purposes for which the Company collects and uses the Personal Information, (ii) the types of third parties to which the Company discloses (or may disclose) that Personal Information, and (iii) the choices and means the Company offers the subjects of the Personal Information for limiting the use and disclosure of their Personal Information.
• Unless permitted by applicable law, no Personal Information is collected without first obtaining the appropriate consent of the individual for the collection, use and disclosure of that Personal Information, in accordance with applicable data privacy laws. In some circumstances the consent for the Company to collect Personal Information may arise from the nature of the relationship between the Company and the individual, or an individual’s interaction with the Company, such as by using a the Company website or engaging in a transaction with the Company.
• The Company will collect your Personal Information only for specified and legitimate purposes as set forth in this Policy. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected.
• The Company will process your Personal Information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented.
• The Company will take commercially reasonable steps to ensure that your Personal Information is reliable for its intended use, accurate, complete, and, where necessary, kept up to date.
• The Company will not use your Personal Information for direct marketing purposes without giving you an opportunity to "opt-out," which is more fully described in this Policy.
• The Company will take appropriate measures, by contract or otherwise, to provide adequate protection for Personal Information that is disclosed to a third party or transferred to another country, including transfers within the Company, as more fully set forth herein.
• When you provide Personal Information to the Company, or otherwise access or use the Websites, Apps, or Messaging modalities, you acknowledge that you have read this Policy and, where required under applicable law, consent to the collection, use and disclosure of your Personal Information in accordance with this Policy and other applicable the Company policies. You may, as provided by applicable law, be free to refuse or withdraw your consent, as more fully described herein.
• the Company, and third parties on its behalf, as more fully set forth herein, use the Personal Information collected from you for purposes such as, but not limited to, user registration; administering and tracking a purchase, payment, return, warranty; arranging for services; inviting participation in online surveys; requesting feedback on products and services; and otherwise communicating with you through various channels.

2. Data Controller, Data Protection Officer, and Representative

The Company is the data controller of the Personal Data you provide on the Websites. The Company has appointed a Data Protection Officer, as identified in Section 22 of this Policy.

The Company is the data controller of your Personal Data. The Company has appointed a Data Protection Officer and a representative in the European Union in compliance with the General Data Protection Regulation. The Company, its Data Protection Officer, or its representative may be contacted in any manner set forth below in the "Contact Information" Section of this Privacy Policy.

3. Children Under the Age of 18

Our Websites are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Websites. We will remove any information about a child under the age of 18 if we become aware of it. 

The Children’s Online Privacy Protection Act ("COPPA"), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. The Websites are restricted to the use of adults over the age of majority in their place of residence. No portion of the Websites is directed to children under the age of 18, and no one under the age of 18 may access, browse, or use the Websites or provide any information to or on the Websites. Consequently, we do not knowingly collect Personal Information from any person under the age of 18. If we learn that we have collected Personal Information from a child under age 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete that information as quickly as possible. If you are a parent or guardian of a child under 18 years of age and you believe your child has provided us with Personal Information, please contact us at privacy@encompass.com for such information collected by a the Company subsidiary.

For more information about COPPA, please visit the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule

4. Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

Generally, We collect several types of information from and about users of our Websites, specifically information:

• by which you may be personally identified, such as your name, billing information, home, work, and/or shipping addresses, work or personal e-mail address, telephone number(s), credit or debit card number (for payment processing only), Federal Tax ID (if you claim that you are tax exempt), your voice (only for audio feedback), or any other identifier by which you may be contacted online or offline ("Personal Information");
• that is about you but individually does not identify you, such as your employer name, title, account number, traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites, error information, clickstream data, and other communication data and the resources that you access and use on the Websites;
• about your internet connection, the equipment you use to access our Websites, and usage details.

We collect this information:

• directly from you when you provide it to us;
• automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies, as described more fully in the "Our Use of Cookies and Other Similar Technologies" section of this Policy as well as in our Cookie Policy, which can be accessed here.

Information You Provide to Us The information we collect on or through our Websites are:

• information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Websites or requesting further services. We may also ask you for information when you enter promotions sponsored by us, and when you report a problem with our Websites;
• your voice recording when you choose to leave us audio feedback;
• records and copies of your correspondence (including email addresses), if you contact us;
• your responses to surveys that we might ask you to complete for research purposes;
• details of transactions you carry out through our Websites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Websites; and
• your search queries on the Websites.

The Personal Information we collect from you is required to enter into a contract with the Company, for the Company to perform under the contract, and to provide you with our products and services. If you refuse to provide such Personal Information or withdraw your consent to our processing of Personal Information, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

• details of your visits to our Websites, specifically traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites, error information, clickstream data, and other communication data and the resources that you access and use on the Websites; and
• Information about your computer and internet connection, specifically your IP address, operating system, and browser type.
• The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Websites and to deliver a better and more personalized service by enabling us to:
• estimate our audience size and usage patterns;
• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Websites according to your individual interests;
• speed up your searches; and
• recognize you when you return to our Websites.

Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie Policy.