Privacy Policy

1. Scope of This Policy

This Policy applies to personal information we process as a business and data controller through:

• This corporate website and any subdomain or landing page operated by us;
• Our contact forms, newsletter subscriptions and investor-relations inquiries;
• Direct-to-consumer storefronts, customer service channels and fulfillment operations run by us or by brands within our portfolio;
• Email, telephone and written correspondence with prospective and existing customers, suppliers, partners and investors.

Individual brands in our portfolio may publish their own store-level privacy notices. Where a brand notice applies to a specific purchase or storefront, that notice governs that transaction and this Policy applies to everything else. This Policy does not apply to third-party websites or platforms we do not control, even where we link to them.

2. Who We Are

The entity responsible for the personal information described in this Policy is:

Throughout this Policy, "Skruzmanis Marketing", "the Company", "we", "us" and "our" refer to the entity above. "You" refers to any individual whose personal information we process.

3. Information We Collect

We collect only the categories of information we genuinely need to operate our business. We do not collect sensitive personal information such as government identification numbers, biometric data, precise geolocation, health records or financial account credentials through this website.

4. How We Obtain It

Information you provide directly

Most of the information we hold is given to us voluntarily: when you complete a contact form, subscribe to our newsletter, place an order with one of our brands, contact customer service, submit a partnership or investor inquiry, or correspond with us by email or telephone.

Information collected automatically

When you visit our website, our servers and limited analytics tooling automatically record technical data such as your IP address, device and browser characteristics, and the pages you view. This information is used in aggregate and, where possible, in a form that does not identify you individually.

Information from third parties

We may receive information about you from payment processors (transaction outcomes and fraud signals), shipping and logistics carriers (delivery status and address validation), e-commerce and marketing platforms we use to operate our storefronts, and publicly available business sources in the context of supplier, partner or investor due diligence.

5. How We Use Information

We use personal information for the following purposes, and only for these purposes:

1. To respond to you. Answering questions, inquiries and requests submitted through our website or other channels.
2. To operate our commercial relationships. Processing and fulfilling orders, arranging dispatch and delivery, handling returns, refunds and warranty claims, and providing customer support.
3. To run and improve our website. Maintaining availability and performance, diagnosing technical faults and understanding in aggregate how our pages are used.
4. To protect our business and our customers. Detecting, investigating and preventing fraud, abuse, security incidents and activity that is unlawful or violates our Terms of Service.
5. To send communications you have requested. Delivering our newsletter, quarterly investor updates and company news to subscribers, subject to the opt-out rights described below.
6. To manage partnerships and investor relations. Evaluating and administering supplier, distribution, partnership and investment discussions.
7. To meet our legal and regulatory obligations. Complying with tax, accounting, consumer protection, product compliance, export and record-keeping requirements in the United States and other jurisdictions where we operate.
8. To establish, exercise or defend legal claims. Where necessary to protect our legal rights or those of our customers, employees or partners.

We do not use personal information for automated decision-making that produces legal or similarly significant effects concerning you, and we do not engage in profiling for such purposes.

6. Legal Bases for Processing (EEA & UK)

Where the EU General Data Protection Regulation (GDPR) or the UK GDPR applies to our processing, we rely on the following legal bases:

• Performance of a contract — to process, fulfill and support an order, or to take steps at your request before entering into a contract.
• Legitimate interests — to operate, secure and improve our business and website, prevent fraud, and communicate with business contacts, where those interests are not overridden by your rights and freedoms.
• Consent — for marketing communications and for non-essential cookies, where consent is required. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Legal obligation — to comply with tax, accounting, consumer protection and other statutory duties.

7. Cookies & Tracking Technologies

Cookies are small text files stored on your device that allow a website to recognize your browser and remember certain information. We use a deliberately limited set of them:

• Strictly necessary cookies — required for the website to function, to maintain session integrity and to protect against fraudulent activity. These cannot be disabled through our site.
• Functional cookies — remember preferences such as language or previously dismissed notices, so you are not asked the same question repeatedly.
• Analytics cookies — help us understand, in aggregate, which pages are visited and how our website performs, so that we can improve it.

You can control cookies through your browser settings, including blocking or deleting them. Disabling strictly necessary cookies may prevent parts of the website from working correctly. Because there is no uniform industry standard for "Do Not Track" signals, our website does not currently respond to them; where required by applicable law, we honor recognized opt-out preference signals such as Global Privacy Control (GPC).

8. Disclosure to Third Parties

We disclose personal information only where there is a clear operational or legal reason to do so, and always under appropriate contractual safeguards. We share information with the following categories of recipients:

• Service providers and processors — web hosting and infrastructure, email delivery, customer service tooling, e-commerce platforms, analytics providers and IT support, each bound to process data only on our documented instructions.
• Payment processors — to authorize and settle transactions and to perform fraud screening.
• Logistics and fulfillment partners — carriers and warehouse operators, who receive the delivery details necessary to dispatch and deliver your order.
• Professional advisers — accountants, auditors, insurers and legal counsel, under duties of confidentiality.
• Portfolio brands and affiliates — entities under common control, where necessary to operate a brand or provide the service you requested.
• Public authorities — where disclosure is required by law, court order, subpoena or a valid governmental request, or where necessary to protect our rights, safety or property.
• Corporate transactions — in connection with a merger, acquisition, financing, reorganization or sale of assets, in which case personal information may be transferred as a business asset subject to the protections of this Policy.

9. No Sale or Sharing of Personal Information

"Sell" and "share" are used here as defined in the California Consumer Privacy Act as amended by the California Privacy Rights Act, and in equivalent U.S. state privacy statutes.

10. Data Retention

We keep personal information only for as long as it is needed for the purpose for which it was collected, and thereafter for as long as required to meet legal, tax, accounting or dispute-resolution obligations. As general guidance:

When personal information is no longer required, we securely delete it or irreversibly anonymize it so that it can no longer be associated with you.

11. Information Security

We maintain administrative, technical and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration and destruction. These include encryption of data in transit (TLS), access controls limiting personal information to personnel with a legitimate business need, vendor due diligence and contractual data-protection commitments, and internal procedures for identifying and responding to security incidents.

No method of transmission over the Internet or method of electronic storage is completely secure. While we work to protect your information using commercially reasonable measures, we cannot guarantee absolute security. If we become aware of a personal data breach that is likely to result in a risk to your rights, we will notify you and the competent authorities where and as required by applicable law.

12. International Data Transfers

We are headquartered in the United States, and our operations, service providers and infrastructure are primarily located there. If you access our website or purchase from our brands from outside the United States, your personal information will be transferred to and processed in the United States, where data protection laws may differ from those of your country of residence.

Where we transfer personal information out of the European Economic Area, the United Kingdom or Switzerland, we do so on the basis of an appropriate safeguard recognized under applicable law, including the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum where relevant), together with supplementary measures where required. You may request a copy of the relevant safeguard by contacting us.

13. U.S. State Privacy Rights

Depending on your state of residence — including California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana and other states with comprehensive privacy legislation — you may have the following rights:

• Right to know or access — to confirm whether we process your personal information and to obtain the categories and specific pieces of information we hold, the sources, the purposes and the categories of recipients.
• Right to delete — to request deletion of personal information we have collected from you, subject to statutory exceptions such as completing a transaction, detecting security incidents or complying with a legal obligation.
• Right to correct — to request correction of inaccurate personal information.
• Right to portability — to receive a copy of your personal information in a portable, readily usable format.
• Right to opt out — of the sale or sharing of personal information and of targeted advertising. As stated in Section 9, we do not engage in these activities.
• Right to limit use of sensitive personal information — we do not collect or use sensitive personal information for purposes that trigger this right.
• Right to non-discrimination — we will never deny you goods or services, charge you a different price, or provide a different level of quality because you exercised a privacy right.
• Right to appeal — where your state provides it, you may appeal a decision we make on your request by replying to our response; we will inform you of the outcome, and of how to contact your state Attorney General if you disagree.

You may use an authorized agent to submit a request on your behalf. We will require written proof of the agent's authority and may ask you to verify your own identity directly.

14. Rights in the EEA, United Kingdom and Switzerland

If you are located in the EEA, the UK or Switzerland, you have the right to access your personal information; to have inaccurate data rectified; to request erasure; to restrict or object to processing, including objecting to direct marketing at any time; to data portability; and to withdraw consent where processing is based on consent.

You also have the right to lodge a complaint with your local supervisory authority, or with the UK Information Commissioner's Office. We would, however, appreciate the opportunity to address your concerns before you approach a regulator.

15. How to Exercise Your Rights

To exercise any of the rights described above, contact us at info@skruzmanisgroup.com with the subject line "Privacy Request", or by telephone at +1 575 251 2976. Please tell us which right you wish to exercise and provide enough information for us to locate your records.

To protect your information, we will take reasonable steps to verify your identity before acting on a request; the verification we ask for will be proportionate to the sensitivity of the information involved. We will respond within the timeframe required by applicable law — generally within 45 days under U.S. state privacy statutes (extendable by a further 45 days where reasonably necessary, with notice to you) and within one month under the GDPR and UK GDPR (extendable by two further months for complex requests). Exercising these rights is free of charge, unless a request is manifestly unfounded, repetitive or excessive.

16. Marketing Communications

We send newsletters, quarterly investor updates and company news only to individuals who have asked to receive them. Every marketing email contains a clear unsubscribe link, and you may also opt out at any time by contacting us directly. Opt-out requests are processed promptly and, in any event, within ten (10) business days as required by the CAN-SPAM Act.

Please note that we may continue to send you non-promotional service messages — such as order confirmations, shipping notifications, returns information, security alerts and changes to our legal terms — because these are necessary to the relationship between us and are not marketing communications.

17. Children's Privacy

Our website and our products are directed to adults and are not intended for children. We do not knowingly collect personal information from anyone under the age of sixteen (16), and we do not knowingly sell or share such information. If you believe a child has provided us with personal information, please contact us and we will delete that information promptly. Where the U.S. Children's Online Privacy Protection Act (COPPA) applies, we treat information about children under thirteen (13) with the heightened protections that statute requires.

18. Third-Party Websites and Services

Our website may contain links to third-party websites, storefronts, social media profiles or payment pages that we do not operate. This Policy does not apply to those services, and we are not responsible for their content or their privacy practices. We encourage you to read the privacy notice of any third-party service before providing personal information to it.

19. Investor and Partnership Communications

Information submitted through our investor-relations and partnership channels is used exclusively to evaluate and administer the relationship in question, to send company updates you have subscribed to, and to comply with our record-keeping and regulatory obligations. It is treated as confidential, is accessible only to personnel and advisers with a legitimate need, and is never used for consumer marketing.

Company updates and materials distributed through these channels are provided for information only and do not constitute an offer to sell or a solicitation of an offer to buy any security. Please see our Terms of Service for the applicable disclaimer.

20. Changes to This Policy

We review this Policy periodically and may update it to reflect changes in our practices, our services, or applicable law. When we do, we will revise the "Last Updated" date at the top of this page. Where a change is material — for example, a new purpose of processing or a new category of recipient — we will provide prominent notice on our website and, where required by law, seek your consent before the change takes effect.

Your continued use of our website after an updated Policy takes effect constitutes acknowledgement of the revised Policy.

21. Contact Us

If you have any question, concern or complaint about this Policy or about how we handle personal information, we want to hear from you. We take every privacy inquiry seriously and aim to acknowledge it within two (2) business days.