CTM GROUP, INC.

PRIVACY POLICY

Last revised: March 15, 2022

CTM Group, Inc. (“We” “Our” or “Us”) takes your privacy very seriously. This Privacy Policy (the “Policy”) applies to the ctmgroupinc.com, atthepierarcade.com and associated web pages (the “Site”) and our information collection practices beyond the Site. By visiting the Site, you accept this Privacy Policy and our Terms of Use, which incorporate the Privacy Policy. If you do not agree, do not use the Site.

This Policy does not apply to information we collect about employees, job applicants, and independent contractors, or individuals when acting as representatives (e.g., employees, contractors) of entities with which we do business.

For purposes of this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  It does not include de-identified or aggregate information, or public information lawfully available from governmental records.

Personal Information Collection.

In the 12 months preceding the date of this Policy, we may have collected your Personal Information if you visited our website and/or requested information about our products or services. Such a request may involve you providing your contact information such as name, business name (if applicable), email address, mailing address, phone number, and similar contact information. This information is generally collected via phone or email or through the Site. We will continue to collect Personal Information from the same sources.

The categories of Personal Information we may have collected from these sources during the 12 months preceding the date of this Policy, and will continue to collect, include the following:

• Personal identifiers: Name, address, email address, telephone numbers, IP address or another unique identifier, account name and password, and other similar information.
• Financial information: Payment or bank account information.
• Commercial information: Records of products purchased or considered, consuming histories or tendencies.
• Internet or other electronic activity information: The length of time spent on certain pages, the website Uniform Resource Locator (“URL”) from the website you were visiting before coming to this Site, which URL you next visit, device type, what browser you are using, Internet service provider, date/time of visit information, operating system, and your Internet Protocol (“IP”) address.
• Inferences drawn from any of the Personal Information identified above.

Uses of Information. Your contact and/or internet or electronic network information may be used any of the following ways:

• Communicating with you regarding your request for information, or to otherwise respond to a request that you have made
• Enforcing our rights arising from any contracts entered into between you and us
• Protecting our rights or property or our safety, our members, or others
• Complying with any court order, legal process, or respond to any governmental or regulatory request
• Transferring information in the event of a merger, transfer of assets or other organizational restructuring
• Monitoring and evaluating our Site and identifying where we should make changes or expand services.

Sharing of Information. We may share your Personal Information with the following categories of third parties:

• Our affiliate companies, for purposes of fulfilling an order or other request.
• Third party analytics companies that help us to monitor traffic on the Site and learn how users are navigating our Site.
• Law enforcement or legal authorities, in response to lawfully served process or subpoena. Occasionally we may be required by law enforcement or judicial authorities to provide personal information. We will disclose information upon receipt of a court order, subpoena, warrant, or other legal process to the extent necessary to meet legal, national security, public interest, or law enforcement obligations. We fully cooperate with law enforcement agencies in identifying those who use the Site for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
• Successor company or companies in the event that we cease operations for any reason. If we enter into an agreement to be purchased by another company or to merge with another company, we may share personal information with that company. We will require that such purchasers continue to comply with the provisions as outlined in this Privacy Policy.

We do not sell your Personal Information.

Cookie Technology. We also may employ cookie technology. A cookie is a string of information that is sent by a website and stored on your hard drive or temporarily in your computer’s memory. Cookies are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

When you use the Site, we may pass several cookies to your computer. The cookies and other tracking technologies may also collect information about your IP address or actions taken in connection with the Site.  We may use cookies or similar tracking technologies to capture information about the use of our Site, including to improve your user experience. Accordingly, we may store and retrieve information on your device through the use of cookies and similar technologies. Your browser may allow you to manage how cookies are handled on websites you visit or allow you to delete cookies. Taking steps to delete cookies may impact your user experience on the Site.

We use Google Analytics to evaluate the use of our website. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website. To learn more about how Google Analytics collects personal information, review Google’s Privacy Policy.

California Privacy Rights

If you are a California resident, you may have separate rights regarding your Personal Information, in accordance with California law.

California Consumer Privacy Act

The California Consumer Privacy Act (CCPA) gives California residents rights described below with respect to their Personal Information.

Your Right To Request Disclosure of Information We Collect and Share About You

We are committed to ensuring that you know what Personal Information we collect. To that end, you can ask us for any or all of following types of information regarding the Personal Information we have collected about you in the 12 months prior to our receipt of your request:

• Specific pieces of Personal Information we have collected about you;
• Categories of Personal Information we have collected about you;
• Categories of sources from which such Personal Information was collected;
• Categories of Personal Information that the business sold or disclosed for a business purpose about the consumer;
• Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
• The business or commercial purpose for collecting or selling your Personal Information.

Your Right To Request Deletion of Personal Information We Have Collected About You 

Upon your request, we will delete the Personal Information we have collected about you, except for situations where the CCPA authorizes us to retain specific information, including when it is necessary for us to provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law.  The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.  We will act on your deletion request within the timeframes set forth below.

Exercising Your Rights and How We Will Respond

To exercise any of the rights above, or to ask a question, you may contact us at 800-951-3320, complete and submit our Data Request Form or use the contact details set out at the end of this Policy.

For requests for access or deletion, we will first acknowledge receipt of your request within 10 business days of receipt of your request.  We provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances.  If we expect your request is going to take us longer than normal to fulfill, we will let you know.

For requests to stop the sale of your Personal Information, we will comply no later than 15 business days after receipt of your request.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.  In some cases, the law may allow us to refuse to act on certain requests.  When this is the case, we will endeavor to provide you with an explanation as to why.

Our Commitment to Honoring Your Rights

If you exercise any of the rights explained in this Policy, we will continue to treat you fairly.  If you exercise your rights under this Policy, you will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services than others.

Verification of Identity – Access or Deletion Requests

We will ask you for identifying information and attempt to match it to information that we maintain about you.

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request.  We will notify you to explain the basis of the denial.

Ensuring Veracity of Requests

If we have a good-faith, reasonable belief that a request to delete Personal Information is fraudulent, we may deny the request.  Should this occur, we will inform you and explain why we believe the request is fraudulent.

Authorized Agents

As a California resident you may designate an agent to submit requests on your behalf.  The agent must be a natural person or a business entity that is registered with the California Secretary of State.

If you would like to designate an agent to act on your behalf, you and the agent will be required to provide us with proof of the agent’s identity and proof that you gave the agent signed permission to submit a request on your behalf.  Additionally, you will be required to verify your identity by providing us with certain Personal Information as described above or provide us with written confirmation that you have authorized the agent to act on your behalf.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney.  Any such requests will be processed in accordance with California law pertaining to powers of attorney.

Requests for Household Information

There may be some types of Personal Information that can be associated with a household (a group of people living together in a single dwelling).  Requests for access or deletion of household Personal Information must be made by each member of the household.  We will verify the identity of each member of the household using the verification criteria explained above and will also verify that each household member is currently a member of the household.

California Shine the Light

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to annually request, free of charge, information about certain categories of Personal Information a business has disclosed to third parties for direct marketing purposes in the preceding calendar year.  We have not disclosed any Personal Information to third parties for direct marketing purposes in the preceding calendar year.

California Do Not Track 

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked.  At this time, our Site does not respond to browsers’ do not track signals.

Security. We are committed to maintaining your confidence and trust and are taking steps to help protect the personal information you provide to us. However, no transmission or electronic storage of information is guaranteed to be secure. We therefore urge you to always use caution when transmitting information over the Internet.

Children. Although features of our Site depict children and games, the Site is directed towards consumers interested in setting up our entertainment solutions. The Site is not directed toward children under 18 years of age nor do we knowingly collect information from children under 18.  If you are under 18, please do not use the Site or submit any personally identifiable information to us.

Third Party Websites. Our Site may contain links to other third-party websites, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policies posted on any website that you may access through our Site.

How We Keep Your Personal Information Secure. We implement and maintain reasonable security measures appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process.  Those measures include administrative, physical and technical safeguards to protect the security, confidentiality and integrity of Personal Information.  However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

International Visitors. We store and process your data in the United States, and we intend our services only to be used in the United States. If you are located in a foreign jurisdiction and do not want to transfer your data to the United States or if it is illegal to transfer or process your data in the United States, please do not use our services.

Changes and Updates. We may revise this Privacy Policy from time to time. We will post any changes on this page and update the date at the top, so be sure to check back periodically to stay aware of any modifications. Your continued use of the Site after changes have been posted will constitute your acceptance of this Privacy Policy and any changes.

Contact Us. If you have any questions, concerns, or suggestions regarding this Privacy Policy, please send us an email to privacy@ctmgroupinc.com or contact us writing at:

CTM Group, Inc.

5 Industrial Way Ste 1A

Salem, New Hampshire 03079