PRIVACY POLICY
Kenberma Products Inc
Effective Date: 7/31/26 | Last Updated: 7/31/26
1. Introduction and Scope
Kenberma Products Inc (“Company,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you visit www.myexchangepromos.com (the “Site”), use our products and services, communicate with us, or otherwise interact with us (collectively, the “Services”).
This Privacy Policy applies to personal information we process as a business or controller — that is, where we determine why and how the information is used. It does not apply to information we process on behalf of our business customers as a service provider or processor; in those cases, our customer's privacy policy governs, and we handle the information in accordance with our contract with that customer.
This Privacy Policy does not apply to information governed by a separate notice, including our Employee and Applicant Privacy Notice, or to third-party websites we do not control.
Please read this Privacy Policy carefully. By using the Services, you acknowledge that you have read and understood it. If you do not agree with our practices, please do not use the Services.
2. Personal Information We Collect
“Personal information” means information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular individual or household. It does not include publicly available information, deidentified or aggregated information, or information excluded from the scope of applicable privacy laws.
We collect the categories of personal information described below. The specific information we collect depends on how you interact with us.
2.1 Categories of Personal Information
|
Category |
Examples |
Collected? |
|
Identifiers |
Name, postal address, email address, telephone number, account name, unique personal identifier, online identifier, IP address[JT1] |
YES |
|
Customer records |
Payment card or financial account information |
YES |
|
Protected classifications |
Age, sex, gender, marital status, veteran or military status, or other characteristics protected under state or federal law |
NO |
|
Commercial information |
Records of products or services purchased or considered, purchasing or consuming histories, order and transaction records |
YES |
|
Biometric information |
Fingerprints, faceprints, voiceprints, iris or retina scans, keystroke or gait patterns used to identify an individual |
NO |
|
Internet / network activity |
Browsing history, search history, pages viewed, referring URLs, clickstream data, and information about interactions with the Site, emails, or advertisements |
YES |
|
Geolocation data |
General location inferred from IP address; precise location if you enable it on your device |
YES |
|
Audio, visual, and similar |
Photographs, video, recorded customer service calls, security camera footage |
NO |
|
Professional or employment |
Employer, job title, business contact details, professional history |
YES |
|
Education information |
Education records not publicly available, where you provide them |
NO |
|
Inferences |
Profiles reflecting preferences, characteristics, behavior, attitudes, or aptitudes drawn from the above |
NO |
|
Sensitive personal information |
See Section 2.2 below |
NO |
2.2 Sensitive Personal Information
Several state laws treat certain categories as “sensitive personal information” or “sensitive data” and require heightened protection. These include:
• Social Security number, driver's license number, state identification card number, or passport number
• Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
• Precise geolocation (generally, location within a radius of 1,750 feet or less)
• Racial or ethnic origin, national origin, citizenship or immigration status, religious or philosophical beliefs, or union membership
• The contents of mail, email, and text messages where we are not the intended recipient
• Genetic data and biometric data processed for the purpose of uniquely identifying an individual
• Personal information concerning health, including consumer health data
• Personal information concerning sex life, sexual orientation, or transgender or nonbinary status
• Personal information of a known child under 13 years of age
• Status as a victim of crime
We do not collect sensitive personal information. We do not use or disclose sensitive personal information for purposes other than those permitted under applicable law, and we do not sell sensitive personal information or use it to infer characteristics about you. Where required by law, we obtain your consent before processing sensitive data, and we do not process the sensitive data of a known minor without the consent required by law.
2.3 Information Collected Automatically
When you visit the Site, we and our service providers automatically collect certain information through cookies, pixels, tags, software development kits, server logs, and similar technologies. This may include your IP address, device identifiers, browser type and settings, operating system, language preference, referring and exit pages, pages viewed, time spent, and interaction data. See Section 8 for details on cookies and your choices.
3. How We Collect Personal Information
We collect personal information from the following sources:
• Directly from you — when you create an account, place an order, complete a form, subscribe to communications, apply for a job, participate in a survey or promotion, or contact us.
• Automatically — through cookies and similar technologies as you interact with the Site, our emails, and our advertisements.
• From service providers and vendors — including hosting, analytics, payment processing, fraud prevention, customer support, and marketing providers.
• From advertising and marketing partners — including advertising networks, data analytics providers, and lead generation sources.
• From publicly available and third-party sources — including public records, social media platforms, and commercially available data sources.
• From other individuals — for example, when someone refers you to us or purchases a product on your behalf.
• In connection with a corporate transaction — such as a merger, acquisition, or asset sale.
4. How We Use Personal Information
We use personal information for the following business and commercial purposes:
• To provide, operate, maintain, and improve the Services, including processing transactions, fulfilling orders, and managing accounts
• To communicate with you, including responding to inquiries, providing customer support, and sending administrative and transactional messages
• To send marketing and promotional communications, subject to your choices and applicable law
• To personalize content, features, and recommendations
• To perform analytics, research, and product development, and to measure the effectiveness of our advertising
• To advertise our products and services, including through targeted or cross-context behavioral advertising where permitted
• To detect, investigate, and prevent fraud, security incidents, and other malicious, deceptive, or illegal activity
• To maintain the safety, security, and integrity of the Services and our systems
• To administer surveys, contests, sweepstakes, and promotions
• To evaluate employment applications, where applicable
• To comply with legal obligations, respond to lawful requests, enforce our terms, and establish, exercise, or defend legal claims
• For any other purpose disclosed to you at the time of collection or to which you consent
We will not use personal information for a materially different purpose than those disclosed above without first providing notice and, where required, obtaining your consent.
We may also create deidentified or aggregated information that cannot reasonably be used to identify you. We maintain and use such information in deidentified form and do not attempt to reidentify it, except as permitted by law.
5. How We Disclose Personal Information
We may disclose each category of personal information described in Section 2 to the following categories of recipients:
• Service providers and processors that perform services on our behalf, including hosting, cloud storage, payment processing, order fulfillment, shipping, analytics, email delivery, customer support, security, and professional advisory services. These recipients are contractually restricted from using personal information for their own purposes.
• Advertising and analytics partners, which may use cookies and similar technologies on the Site. Depending on your choices, disclosures to these partners may constitute a “sale” or “sharing” of personal information, or processing for “targeted advertising,” under state law. See Sections 6 and 8.
• Affiliates and subsidiaries within our corporate family, for the purposes described in this Privacy Policy.
• Business partners, where you request or consent to a jointly offered product, promotion, or service.
• Professional advisors, including attorneys, auditors, accountants, and insurers.
• Government authorities, courts, and law enforcement, where we believe disclosure is necessary or appropriate to comply with law, respond to lawful requests or legal process, protect our rights or property, or protect the safety of any person.
• Acquirers and other parties to a corporate transaction, including in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets.
• Other parties with your direction or consent, including where you choose to make information public through the Services.
We do not disclose personal information to third parties for their own independent marketing purposes without providing you notice and an opportunity to opt out, and, where required by law, obtaining your consent.
6. Sale, Sharing, and Targeted Advertising
Certain state privacy laws define a “sale” broadly to include disclosing personal information to a third party in exchange for anything of value — not only money. Under California law, “sharing” refers to disclosing personal information for cross-context behavioral advertising. Other states use the term “targeted advertising.”
We do not sell or share personal information, and we do not process personal information for targeted advertising. We have not sold or shared personal information in the preceding 12 months. We do not knowingly sell or share the personal information of consumers under 16 years of age.
You may opt out of these activities at any time. See Section 7 (Your Privacy Rights) and Section 8.3 (Opt-Out Preference Signals).
7. Your Privacy Rights
Depending on where you live, you may have some or all of the rights described below. We extend the following rights to all U.S. residents, regardless of state, except where a right is available only under a specific state's law or an exception applies.
7.1 Rights Available
• Right to know / access — to confirm whether we process your personal information and to obtain access to it, including the categories collected, the sources, the purposes, the categories of recipients, and the specific pieces of personal information we hold.
• Right to a portable copy — to obtain a copy of personal information you provided to us in a portable and, to the extent technically feasible, readily usable format.
• Right to correct — to request correction of inaccurate personal information, taking into account the nature of the information and the purposes of processing.
• Right to delete — to request deletion of personal information we have collected from or obtained about you.
• Right to opt out of sale or sharing — to direct us not to sell or share your personal information.
• Right to opt out of targeted advertising — to direct us not to process your personal information for targeted or cross-context behavioral advertising.
• Right to opt out of profiling — to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, such as decisions about credit, housing, insurance, education, employment, or access to essential goods and services.
• Right to limit use of sensitive personal information — to limit our use and disclosure of sensitive personal information to purposes permitted under California law.
• Right to withdraw consent — to withdraw consent previously given, including consent to process sensitive data. Withdrawal does not affect the lawfulness of processing before withdrawal.
• Right to a list of third parties — in certain states, including Oregon and Minnesota, to obtain a list of the specific third parties (or, at our option in some states, the categories of third parties) to which we have disclosed personal information.
• Right to question profiling results — in Minnesota, if we use profiling in furtherance of decisions producing legal or similarly significant effects, to be informed of the reason the profiling resulted in the decision, to be informed of what actions you might have taken to secure a different outcome, to review the personal information used, and to have that data corrected and the decision reevaluated.
• Right to non-discrimination — we will not discriminate against you for exercising any privacy right, including by denying goods or services, charging different prices, or providing a different level or quality of service. We do not offer financial incentives in exchange for personal information.
• Right to appeal — to appeal a decision declining to act on your request. See Section 7.4.
7.2 How to Submit a Request
You may submit a request by:
• Email: april@kenberma.com
• Toll-free telephone: 1-800-343-5978
• Mail: Kenberma Products Inc Attn: Privacy, 5 Suosso Ln Plymouth MA 02360
To opt out of the sale or sharing of personal information or of targeted advertising, you may also use the link titled “Do Not Sell or Share My Personal Information” on the Site, or transmit an opt-out preference signal as described in Section 8.3. To limit our use of sensitive personal information, use the link titled “Limit the Use of My Sensitive Personal Information,” where applicable.
7.3 Verification and Authorized Agents
You may designate an authorized agent to submit a request on your behalf. We may require the agent to provide proof of your written permission and may require you to verify your own identity directly with us or to confirm that you granted the agent permission, except where the agent provides a valid power of attorney.
A parent or legal guardian may submit a request on behalf of a minor child.[JT2]
7.4 Our Response and Your Right to Appeal
We will acknowledge and respond to verified requests within 45 days. Where reasonably necessary, we may extend that period by an additional 45 days (or, in some states, 60 days) and will notify you of the extension and the reason for it. We provide the response free of charge unless the request is manifestly unfounded, excessive, or repetitive, in which case we may charge a reasonable fee or decline to act, and will explain why.
In responding to a request to know, we will provide personal information covering the 12-month period preceding the request, and, where required by California law and technically feasible, for periods beyond 12 months, unless doing so would be impossible or involve disproportionate effort.
We may deny a request in whole or in part where an exception applies — for example, where the information is necessary to complete a transaction, detect security incidents, comply with a legal obligation, or exercise or defend legal claims, or where the information is exempt under a law such as the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, HIPAA, the Driver's Privacy Protection Act, or the Family Educational Rights and Privacy Act.
Appeals. If we decline to act on your request, you may appeal within a reasonable period by writing to april@kenberma.com with the subject line “Privacy Request Appeal.” We will respond in writing within 45 days (60 days in some states) with an explanation of the reasons for our decision. If your appeal is denied, you may contact your state Attorney General to submit a complaint. Contact information will be provided in our appeal response.
8. Cookies, Analytics, and Tracking Technologies
8.1 Technologies We Use
• Strictly necessary — required to operate the Site, authenticate users, maintain sessions, and provide security. These cannot be disabled through our preference tool.
• Functional — remember your preferences and settings.
• Analytics and performance — help us understand how the Site is used so we can improve it.
• Advertising and targeting — used by us and our partners to deliver and measure advertising, including advertising based on your activity across different websites and over time.
We also use pixels and web beacons in emails to determine whether messages were opened and links clicked, and software development kits in any mobile applications.
8.2 Your Cookie Choices
• Opt out of interest-based advertising through the Digital Advertising Alliance (optout.aboutads.info), the Network Advertising Initiative (optout.networkadvertising.org), and, for mobile, the DAA AppChoices app
• Adjust the advertising identifier settings on your mobile device[JT3]
Opting out of interest-based advertising does not mean you will stop seeing advertising; it means the advertising you see will be less tailored to you. Because these opt-outs are typically cookie- or device-based, you will need to renew them if you clear cookies, change browsers, or use a different device.
9. Retention of Personal Information
We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide the Services, maintain business records, resolve disputes, enforce agreements, and comply with legal, tax, accounting, and regulatory obligations. We do not retain personal information for longer than reasonably necessary for the disclosed purpose.
In determining retention periods, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether those purposes can be achieved by other means, and applicable legal requirements. Illustrative retention periods:
|
Category |
Retention Period |
Basis |
|
Account information |
Duration of account plus 7 years |
Service delivery; recordkeeping |
|
Transaction records |
Indefinitely |
Tax, accounting, and audit obligations |
|
Marketing contacts |
Until opt-out |
Consent management; suppression lists |
|
Website analytics data |
12 months |
Product improvement |
|
Support communications |
7 years |
Dispute resolution; quality assurance |
|
Job applicant records |
2 years |
Legal recordkeeping obligations |
When retention is no longer necessary, we delete or deidentify the information, or securely isolate it where deletion is not technically feasible (for example, in backup archives), until deletion is possible.
10. Data Security
We maintain reasonable administrative, technical, physical, and organizational safeguards designed to protect personal information against unauthorized access, use, alteration, disclosure, and destruction. These measures are appropriate to the volume, scope, and nature of the personal information we process and the nature of our business, and may include encryption in transit and at rest, access controls, network monitoring, vendor due diligence, employee training, and incident response procedures.
No method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security. You are responsible for maintaining the confidentiality of any account credentials and for notifying us promptly at april@kenberma.com if you believe your account has been compromised.
If a security incident affecting your personal information occurs, we will notify you and the applicable regulators as required by the breach notification laws of your state and any other applicable law.
11. Children's Privacy
The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13 in violation of the Children's Online Privacy Protection Act (COPPA). If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete it promptly. A parent or guardian who believes their child has provided us personal information may contact us april@kenberma.com.
We do not knowingly sell or share the personal information of consumers under 16 years of age, or process the personal information of a known minor for targeted advertising, without the opt-in consent required by applicable law — from the consumer if they are between 13 and 16, or from a parent or guardian if the consumer is under 13.
If you are a California resident under 18 and a registered user of the Site, you may request removal of content or information you have publicly posted by contacting us at april@kenberma.com. Removal may not be complete or comprehensive, and the content may remain in backup or archival copies or have been copied by others.
12. State-Specific Disclosures
The following disclosures supplement the rest of this Privacy Policy and apply to residents of the states identified. Where a state's law grants you a right described in Section 7, that right applies to you whether or not the state is named again below.
12.1 California
This section applies to California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA). The categories of personal information we collect, the sources, the business and commercial purposes, the categories of third parties to whom we disclose, and the retention periods are described in Sections 2, 3, 4, 5, and 9. Your rights and how to exercise them are described in Section 7.
Shine the Light. California Civil Code § 1798.83 permits California residents to request information about disclosures of personal information to third parties for those parties' own direct marketing purposes. [We do not disclose personal information to third parties for their direct marketing purposes. / To make a request, contact us at april@kenberma.com.
Notice of Financial Incentive. We do not offer financial incentives or price or service differences in exchange for the retention or sale of personal information. [JT4]
12.2 Virginia, Colorado, Connecticut, Utah, and Other Comprehensive-Law States
Residents of states with comprehensive consumer privacy laws — including Virginia, Colorado, Connecticut, Utah, Iowa, Indiana, Tennessee, Montana, Texas, Oregon, Florida, Delaware, New Jersey, New Hampshire, Kentucky, Nebraska, Rhode Island, Minnesota, and Maryland — have the rights described in Section 7, subject to the specific provisions and exemptions of their state's law. Certain rights are not available in every state; for example, Utah and Iowa do not provide a right to correct, and appeal rights vary by state.
Where required by state law, we conduct and document data protection assessments for processing activities that present a heightened risk of harm, including targeted advertising, the sale of personal information, certain profiling, and the processing of sensitive data.
12.3 Texas, Oregon, Nebraska, and Florida Notice
We do not sell personal data to third parties or process personal data for targeted advertising.
12.4 Oregon and Minnesota — Third-Party Lists
Oregon residents may request a list of the specific third parties, other than natural persons, to which we have disclosed personal data. Minnesota residents may request a list of the specific third parties to which we have disclosed their personal data or, if we do not maintain that information, a list of the specific third parties to which we have disclosed any personal data. Submit these requests through the methods in Section 7.2.
12.5 Maryland
For Maryland residents, we do not sell sensitive data, and we do not collect, process, or share sensitive data except where strictly necessary to provide or maintain a specific product or service requested by the consumer. We do not sell the personal data of, or process for targeted advertising the personal data of, a consumer we know or should know is under 18.
12.6 Washington, Nevada, and Connecticut — Consumer Health Data
The Washington My Health My Data Act, the Nevada consumer health data law, and Connecticut's health data provisions regulate “consumer health data,” broadly defined to include information that identifies a consumer's past, present, or future physical or mental health status — including bodily functions, health conditions, health-related purchases, precise location that could indicate an attempt to acquire health services, and inferences drawn from any of the above.
We do not collect, process, sell, or share consumer health data as defined by these laws.
Washington and Nevada residents may exercise the rights described in Section 7 with respect to consumer health data, including the right to withdraw consent and the right to have such data deleted. We do not sell consumer health data without valid written authorization, and we do not use a geofence around any facility providing health care services.
12.7 Nevada — Sale of Covered Information
Nevada Revised Statutes Chapter 603A permits Nevada consumers to submit a verified request directing us not to make any sale of certain covered information we have collected about them. We do not sell covered information as defined by Nevada law. To submit a request, email april@kenberma.com with the subject line “Nevada Do Not Sell Request” and include your name and the email address associated with your account.[JT5]
12.8 Illinois, Texas, and Washington — Biometric Information
We do not collect, capture, purchase, receive through trade, or otherwise obtain biometric identifiers or biometric information.
12.9 New York and Other States — Website Terms
New York General Business Law requires operators of websites collecting personal information from New York consumers to post a conspicuous privacy policy describing the categories of information collected, the categories of third parties with whom it may be shared, and the process for reviewing and requesting changes to that information. Those disclosures appear in Sections 2, 5, and 7 of this Privacy Policy.
12.10 States Without Comprehensive Privacy Laws
If you reside in a state that has not enacted a comprehensive consumer privacy law, we will honor requests to access, correct, delete, or opt out of the sale of your personal information on the same terms described in Section 7, to the extent reasonably practicable and subject to applicable legal exceptions. We extend these rights as a matter of policy, and doing so does not waive any exemption or defense available to us.
13. Financial, Health, and Other Regulated Information
Certain information is regulated by federal or state sector-specific laws and is exempt from, or treated differently under, state consumer privacy laws. Where applicable, our handling of the following is governed by the laws identified rather than by this Privacy Policy: protected health information under HIPAA; nonpublic personal information under the Gramm-Leach-Bliley Act and applicable state financial privacy laws; consumer report information under the Fair Credit Reporting Act; education records under FERPA; and motor vehicle records under the Driver's Privacy Protection Act.
14. Individuals Outside the United States
The Services are directed to individuals located in the United States. We store and process personal information in the United States and in other countries where our service providers operate. If you access the Services from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction.
15. Third-Party Websites and Services
The Services may contain links to, or integrations with, websites, applications, and services operated by third parties, including social media platforms and payment processors. We do not control and are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party service you use.
16. Accessibility
We are committed to making this Privacy Policy accessible to individuals with disabilities. If you use an assistive technology and have difficulty accessing this Privacy Policy, please contact us at april@kenberma.com or 1-800-343-5978 and we will provide the information in an alternative format.
17. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date above and post the revised policy on the Site. If we make material changes, we will provide additional notice, such as by email or a prominent notice on the Site, and, where required by law, obtain your consent. We will not apply materially different practices to personal information collected before the change without providing notice and, where required, obtaining consent. Your continued use of the Services after the effective date of a revised policy constitutes acknowledgment of the changes.
18. Contact Us
If you have questions, concerns, or complaints about this Privacy Policy or our privacy practices, or wish to exercise your rights, contact us at:
Kenberma Products Inc
Attn: Privacy
5 Suosso Ln
Plymouth, MA 02360
Email: april@kenberma.com
Telephone: 1-800-343-5978
If you are not satisfied with our response, you may have the right to lodge a complaint with your state Attorney General or, for California residents, with the California Privacy Protection Agency.