Nepa Wholesale Inc. Your Privacy Rights

(United States and Puerto Rico)

Last Updated December 11, 2023

This Privacy Notice explains our collection, use, and disclosure of personal information. This Privacy Notice applies to Nepa Wholesale Inc. United States (US) and Puerto Rico subsidiaries ("Nepa," "we," “our” or "us").

This Privacy Notice applies when you: access or use our websites or mobile applications (including the Nepa App) that link to this Privacy Notice; become a Nepa member; shop at our warehouses; and contact or otherwise interact with us (collectively, the “Services”). This Privacy Notice does not apply to content or sites operated by other companies that are linked to or from the Services, or to any products, mobile applications, or services provided by third parties.

PERSONAL INFORMATION WE COLLECT

The personal information we collect depends on how you interact with us, the Services you use, and the choices you make.

Information you provide directly. We collect the personal information you provide to us. For example:

• Contact information. We collect name, username, email address, postal address, and phone number.
• Identification information. If you are a member or sign up to be a member, we may collect identity document information (e.g., driver’s license, passport, or tax information) and employer name (if you sign up for membership via your employer).
• Demographic information. In some cases, we request that you provide your age or gender. We may request information regarding veteran status.
• Payment information. If you make a purchase or other financial transaction, we collect payment card numbers, financial account information, billing address, and other payment details.
• Feedback or response information. If you provide feedback through the Services, or if you respond to a survey or other communication from Nepa or its vendors, we collect your response information, including the content of your feedback or response message.
• Chat Features. When you use the virtual assistant or chat features on our Services, you provide consent for us to collect the content of your chat (that is, the words you type into the chat feature and the responses you receive).

Information we collect automatically. When you access or use our Services, we collect some information automatically. For example:

• Transaction and purchase information. When you make a purchase or return, or another financial transaction, we collect information about the transaction. This may include, among other things, product details, purchase price, date, tender type, location of the transaction, shipping/delivery details, and payment type and payment authorization. It may also include account notes about the transaction, including information that helps us prevent fraud, misuse of the Services, or illegal activity.
• Identifiers and device information. When you visit our internet-based Services or use our apps, our web servers automatically log your Internet Protocol (IP) address and information about your device, including unique device identifiers (such as MAC address); device type; and your device’s operating system and version, browser type and language, and other software including type, version, language, settings, and configuration, and mobile network information. As further described in the Cookies, Mobile IDs, and Similar Technologies section below, our websites, apps, and other online services store and retrieve cookie identifiers, mobile IDs, and other information.
• Geolocation information. We may collect or infer information about your approximate or precise location when you access or use the Services, visit our warehouses, or turn on Bluetooth, Wi-Fi or other geolocation functionality on your device.
• Guest Wireless Access. When you connect to guest wireless internet service provided at our locations, we automatically log your activity on that connection, including time, date, and duration of your connection and information that identifies your device. We use this information to protect our networks and to detect potential unauthorized activities.
• Usage and session information. We automatically log your activity on our websites, apps and other Services, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our Services. We capture the screen images that you view and collect information about how you interact with particular screens with your keyboard, mouse, or other input device. We also collect information about what products and services you browse, search for, or otherwise express an interest in, and we track your activity on our Services where our advertising is served. We collect and use such information to evaluate the effectiveness of our Services and marketing, troubleshoot and improve our Services, provide customized marketing messages, customize our advertising, and personalize and improve your experience.
• Call recordings and chat transcripts. We record and store telephone calls and chat transcripts for a period of time when you interact with us by phone or chat, or if you provide us feedback about our Services.
• Video and other images. We use cameras in and around our warehouses and facilities to capture video and images. These may include images of persons inside or around our facilities and parking lots, and photographs of your face taken when checking out or retrieving products from lockers or at member service locations. This also may include facial images and measurements captured when you use the virtual eyeglasses feature on our website.
• Automated License Plate Readers. We may collect images of your license plate and other vehicle information if you drive or park on or near our facilities. For more information about our use and capture of license plate numbers, please see the Automated License Plate Recognition section of this notice.

Information we create or generate. We generate new information relating to you by analyzing data we collect, including using automated means and third-party sources, to create inferences about your likely preferences or other characteristics (“inferences”). For example, we may use information about your previous purchases to infer the types of products and services that may interest you in the future. We use such information to measure and improve our marketing efforts, including providing targeted advertising and other promotional materials to you.

Information concerning minors. We do not direct the Services to individuals under the age of eighteen (18). We do not knowingly collect personal information from individuals under 18.

COOKIES, MOBILE IDs AND SIMILAR TECHNOLOGIES

Nepa and our vendors, suppliers, and advertising providers use digital trackers. Digital trackers include cookies, pixels, and web beacons placed on our websites, advertising Identifiers accessed on your mobile device, and collection of your IP addresses when you use our Services. We use these trackers to collect personal information about you and your online activities over time and across different websites or services.

Why we use digital trackers.

Digital trackers have different functions, including:

• Strictly Necessary trackers are needed for our websites or applications to function. They enable core functions like carrying out network transmissions and enabling you to log in to our systems. They also enable us to maintain your privacy choices by preventing advertising-related or other optional digital trackers from being placed on your browser or device. Strictly necessary cookies cannot be switched off through our Services.
• Functional trackers allow us to provide personalization and convenience features, such as remembering your login information or preferred warehouse location.
• Performance trackers allow us to count visits and traffic sources so we can measure and improve the performance of our Services. They help us to know which pages are the most and least popular and see how visitors move around the site.
• Targeted advertising trackers may be set through our services by us or by third party service providers and advertisers. We use these trackers to collect information about how you use our Services, as well as how you interact with advertisements and content on other websites. This information is used to provide you with advertisements tailored to your interests. If you do not allow these trackers on our Services, you may still receive advertisements, but you may receive less relevant advertising or content.

How to Manage Digital Trackers.

You can opt out of digital trackers placed by our Services for targeted advertising by visiting our Cookie Settings page. Your choice to opt out of targeted advertising trackers is specific to the device, website, and browser you are using, and is deleted when you clear your browser’s cookies.

Because our Services rely on strictly necessary, functional, and performance trackers, you cannot opt-out of those trackers through Cookie Settings on our Services. In most cases, you can disable such trackers through your browser or device settings. If you choose to disable these trackers, it will affect how our Services function and may prevent you from using certain features.

You also may be able to opt out of use of your information for advertising by interacting directly with our analytics and advertising providers or by utilizing association opt-out mechanisms:

NAI (http://optout.networkadvertising.org)

DAA (http://optout.aboutads.info/)

Google Analytics (at www.google.com/policies/privacy/partners/)

OUR USE OF PERSONAL INFORMATION

We use the personal information we collect for purposes described in this Privacy Notice or otherwise disclosed to you. For example, we use personal information for the following purposes:

• Product and service delivery. To provide our products and services, including: securing, troubleshooting, improving, and personalizing products and services, and processing, fulfilling, shipping, and delivering your orders.
• Business operations. To operate our business, such as: creating, maintaining, and renewing your membership, billing, accounting, improving our internal operations, securing our networks and systems, detecting fraudulent, illegal, or unauthorized activity, and monitoring trends, usage and activities in connection with our Services and warehouses.
• Product improvement, development and research. To improve our products, develop new products or features, and conduct research
• Personalization. To understand you and your preferences, to enhance your experience and enjoyment using our products and services and personalize your online experience and the advertisements you see when you use the Services or other platforms.
• Customer support. To send you information and notices about your membership account such as updates, order confirmations, delivery and pick-up notices, security alerts, and support and administrative messages.
• Marketing and advertising. To create marketing materials; to communicate with you about Nepa and other companies’ products and services, offers, promotions, rewards, contests, upcoming events, and other information about our products and services and those of other selected companies; and to display advertising to you.
• Legal, security and safety reasons. For legal, security and safety reasons, such as to protect our rights and the rights of our customers and members, protect the security of our systems and networks, enforce our policies, communicate product recalls or safety notices, or address legal and regulatory compliance obligations.
• For any other purpose described to you at the time information is collected.

We combine information we collect from different sources to achieve these purposes and to give you a more seamless, consistent, and personalized experience.

OUR DISCLOSURE OF PERSONAL INFORMATION

We disclose personal information we collect to complete your transactions, provide the Services, or fulfill orders or inquiries you have requested or authorized. For example, when you provide payment information to make a purchase, we will disclose that information with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services. We may also disclose personal information for additional purposes, such as:

• Primary member. Each Nepa membership account has a primary member or accountholder.
• Business affiliate members. In some circumstances, we may disclose primary members’ or contact and purchase information to business affiliate members associated with the account.
• Account administrators. If you designate an administrator to manage your account, we disclose contact information for primary account members with that administrator.
• Other companies with which you engage. When you request information about, or purchase products or services offered by, other companies as part of your Nepa membership, we disclose information with those companies. We do this so that they may provide you with their products and services, provide customer service, resolve complaints, provide installation and warranty services, and provide recall or emergency notices. We also may disclose information about you with companies that offer their products and services for our and their marketing purposes, such as co-branded companies or joint marketing partners. We may disclose contact information with these other companies so that we or they can notify you of product and service offerings, determine if you qualify for products or services, and evaluate new and existing products or services offerings
• Our affiliates and entities that belong to Nepa’s corporate group. We disclose personal information with our subsidiaries, corporate affiliates, and related companies under common control and ownership.
• Marketing, advertising and analytics providers. We disclose information with other companies that conduct marketing and advertising services to promote our and our suppliers’ products and services. This includes directing digital (online) targeted advertising and other marketing offers, promotions, rewards, contests, upcoming events, and notices to you. We also may use images taken in or around our facilities in marketing materials and advertisements.
• Tobacco rebates for business members. For Business Members who purchase tobacco products for resale, we provide member name, address, brand name, and the amount of tobacco products purchased to the tobacco manufacturers’ representative to process retail incentives. If you are a Business Member in California and you do not want us to provide this information, you can contact us using the methods described in the “Your Privacy Choices” section below.
• Other uses and disclosures. We also will access, transfer, disclose, and preserve personal information when we believe that doing so is necessary to:

• • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
  • Protect our Nepa companies, our shoppers, members, employees or the public; for example, to prevent attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
  • Demonstrate our compliance with applicable laws and regulatory requirements:
  • Operate and maintain the security of our locations and systems, including to prevent or stop an attack on our computer systems or networks; or
  • Protect the rights or property of Nepa or others, including detecting, investigating, and preventing illegal or unauthorized activities, reporting such activities to law enforcement, and enforcing our agreements, terms, and policies.

Deidentified Information. We may aggregate or deidentify information that is no longer personal information. Where we maintain deidentified information, we commit to maintaining and using such information in deidentified form, and will not attempt to reidentify such information except as necessary to evaluate the effectiveness of our deidentification policies and procedures and procedures.

STATE-SPECIFIC PRIVACY RIGHTS

You may have additional privacy rights under the law of the state in which you live. This section describes those rights for residents of Virginia, Colorado, Connecticut, and Nevada. 

VIRGINIA, COLORADO, AND CONNECTICUT

You have the right to access, delete, and correct certain personal information we collect about you. When you request access to personal information, you have the right to receive that information in a portable and readily usable format. You also have the right to restrict the use of that personal information for targeted advertising, restrict the sale of that personal information, and control our use of personal information considered sensitive. You also have a right not to receive discriminatory treatment for the exercise of your privacy rights.

You or your authorized agent may submit a request to exercise your access, deletion, and correction rights by submitting a Data Rights Request or calling 1-800-605-3364. If we deny your request, you have the right to appeal our decision.

To opt out of targeted advertising and the sale or sharing of personal information, please visit our “Your Privacy Choices” webpage.

Nepa will request your consent for processing sensitive personal information. You may revoke your consent at any time. For example, you may revoke your consent to the use of device precise location information through our app by turning off the precise location feature in the app settings on your device.

NEVADA

Residents of Nevada have the right to opt out of the sale of certain types of their information to other companies who will sell or license their information to others. At this time, Nepa does not engage in such sales. If you are a Nevada resident and would like more information about our privacy practices, please email admin@nepawholesale.com.

SECURITY OF PERSONAL INFORMATION

We take what we believe to be reasonable and appropriate steps to help protect personal information from unauthorized access, use, disclosure, alteration, and destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure, and therefore we are unable to guarantee the security of your personal information.

CHANGES TO THIS PRIVACY NOTICE

We will update this Privacy Notice when necessary to reflect changes in our Services, how we use personal information, or the applicable law. When we post changes to this Privacy Notice, we will revise the "Last Updated" date at the top of the Privacy Notice. If we make material changes to the Privacy Notice, we will provide notice or obtain consent regarding such changes as may be required by law.

HOW TO CONTACT US

If you have a privacy concern, complaint, or a question, please contact us at admin@nepawholesale.com or write us at 4365 Okeechobee Blvd, West Palm Beach, FL 33409.