This U.S. Supplemental Privacy Policy (the “Supplemental Policy”) describes the practices of Tradewater, LLC (“Tradewater,” “we,” “us,” or “our”) regarding the collection, use, and disclosure of Personal Information, through both online and offline interactions, including via our websites at https://tradewater.co/, https://refrigerantfinders.com/, and https://cnc.tradewater.us/, about residents of U.S. states with comprehensive state privacy laws that apply to Tradewater (collectively, “U.S. Privacy Laws”). Some portions of this Supplemental Policy apply only to residents of particular states. In those instances, we have indicated that such language applies only to those residents. 

Please note that this Supplemental Policy does not apply to individuals with whom we interact in an employment-related context. Further, except for California residents, this Supplemental Policy does not apply to Personal Information we process about individuals with whom we interact in a business context. 

If you have a disability and need to access this policy in an alternative format, please contact us at info@tradewater.us.  

 A. Definitions

• “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. 

• “Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s Personal Information to a Third Party for monetary or other valuable consideration. 

• “Share,” “Shared,” “Sharing” or “Targeted Advertising” means transferring an individual’s Personal Information to a Third Party for cross-context behavioral advertising or targeted advertising purposes, whether or not for money or other valuable consideration. 

• “Third Party” means any non-affiliated person that is not a Vendor.  

• “Vendor” means a service provider, contractor, or processor which collects, stores, or otherwise handles data for us and is bound by contractual obligations to use your Personal Information only as directed by us. 

You may be familiar with different terms that are used to describe materially similar concepts in this section by the U.S. Privacy Laws in your state of residence. You can treat them as the same for the purpose of our Supplemental Policy. For example, we intend the term “Personal Information” here to have the same definition as “Personal Data” used in some U.S. Privacy Laws. 

 B. Collection& Processing of Personal Information

We, and our Vendors, collect and have collected in the past twelve months the following categories of Personal Information:  

1. Identifiers, such as your name, postal address, e-mail address, or any other identifier by which you may be contacted online or offline.

2. Financial Information, including bank account number, credit card number, debit card number, or any other financial information that does not allow access or withdrawal of funds.

3. Characteristics of Protected Classifications under state or federal law, such as age, gender, and marital status.

4. Commercial Information, such details of transactions you carry out using our Services and of the fulfillment of your orders.

5. Internet or Other Network Information, such as IP address, device identifiers, browsing history, search history, and information regarding your interactions with our websites or advertisements.

6. Geolocation Data, such as device location or any other location shared with us that is more granular than a city or town.

7. Audio, Electronic, Visual, and Similar Information, such as call and video recordings.

8. Professional or Employment-Related Information, such as work history and prior employer.

9. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

We do not collect Sensitive Personal Information or process Sensitive Personal Information for purposes not permitted by the CCPA. 

C. Purposes for Processing and Disclosing Personal Information

We, and our Vendors, collect, process, and disclose the categories of Personal Information listed in Section B, and we have collected, processed, and disclosed such categories of Personal Information in the past twelve months, for the following business purposes: 

• To present our Services to you and others, including the content, features, applications and functionalities made available via our Services; 

• To operate, manage, and maintain our business; 

• To provide, develop, improve, repair, and maintain our services; 

• To conduct research, analytics, and data analysis;  

• To provide you with information about how you can participate in our objective to aid the environment by reducing carbon emissions and other matters that you may be interested in; 

• To provide you with notices about your account; 

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; 

• To notify you about changes to our Services; 

• To allow you to participate in interactive features provided through our Services; 

• To stay in touch with our supporters about activities and to expand our supporter base; 

• To conduct risk and security controls and monitoring;  

• To perform identity verification;  

• To maintain records; 

• In any other way we may describe when you provide the information; 

• To otherwise accomplish our business purposes and objectives; 

• To comply with any internal policies, court order, law or legal process, including to respond to any government or regulatory request; 

• To exercise and defend legal claims; 

• To enforce our Terms and Conditions; 

• To perform accounting, audit, and other internal functions, such as internal investigations;  

• To transfer to a company that Tradewater is acquired by or merges with; or 

• If we believe disclosure is necessary or appropriate to protect the rights, property or safety of us or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction

D.  Data Retention

We store the Personal Information we collect for as long as is necessary for the purpose(s) for which we collected it and in accordance with applicable law and our legitimate business interests. When assessing the data retention period, we take into account the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the Personal Information, whether we can achieve those purposes through other means, and the applicable legal requirements. 

E. Sale, Sharing, & Targeted Advertising

We Sell, Share, and process for Targeted Advertising purposes network activity information, such as online browsing history and interactions with our websites or advertisements, and we have Sold, Shared, and processed for Targeted Advertising this category of Personal Information in the past twelve months. We Sell, Share, and process for Targeted Advertising this category of Personal Information to marketing and analytics providers to analyze and better understand consumers’ needs, preferences, and interests, and to advertise and promote our products and services. You can opt out of the Sale, Sharing, and processing for Targeted Advertising of your Personal Information by clicking here and then clicking “Reject All.”

Additionally, we do not have actual knowledge that we Sell or Share Personal Information of consumers who are under 16 years of age. We also do not process Personal Information for purposes of profiling or to engage in automated decision making in furtherance of decisions that produce legal or similarly significant effects (which means a decision that results in the provision or denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health-care services, or access to essential goods or services).  

F. Disclosures of Personal Information

We disclose, and we have disclosed in the past twelve months, the categories of Personal Information listed in Section B, above, in the following contexts: 

• To our Vendors. We disclose the Personal Information we collect to our vendors who act on our behalf. For example, we use vendors to operate our Services, process payments, and to help us with our promotional efforts. These vendors may need Personal Information about you to perform their obligations. We impose contractual limitations on our vendors’ use of Personal Information they collect in conjunction with providing services to us. 

• To Third Parties for Marketing Purposes. We disclose Personal Information to third parties, including social media platforms and other advertisers, for marketing purposes. This includes disclosures of Personal Information via Cookies, as explained in more detail above. 

• As Described in a Privacy Notice or With Your Consent. We may disclose Personal Information as described in any privacy notice we provide to you via our Services, or with your consent if we obtain it from you in a particular context. 

• In Aggregate or De-Identified Form. We may aggregate or de-identify any of the categories of Personal Information we collect. When we do so, we take reasonable measures to ensure that the information cannot be associated with a consumer or household, and we maintain and use the information in de-identified and/or aggregated form. We will not attempt to re-identify the information, except that we may attempt to re-identify the information solely for the purpose of determining whether our deidentification processes satisfy applicable legal requirements. After it has been de-identified, the information is no longer Personal Information and is not subject to this Policy. We may disclose aggregated and/or de-identified information to our vendors, other companies within our family of businesses, and to third parties for our business operational purposes and for any other purposes permitted by applicable law.  

We may also disclose Personal Information in the following contexts: 

• As Part of a Business Transfer. We may disclose Personal Information to a successor organization if, for example, we transfer the ownership or operation of all or a portion of our Services to another organization, we merge with or are acquired by another organization, or if we liquidate our assets. If such a transfer occurs, we will seek assurances that the successor organization will treat the Personal Information we disclose to it in accordance with this Supplemental Policy. 

• To Comply with Laws and Protect Our Rights and the Rights of Others. We may disclose Personal Information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose Personal Information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Services; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property, or safety of our users or others. 

G. Data Subject Rights

Residents who reside in states with U.S. Privacy Laws, such as California, Nebraska, and Texas, have the following rights regarding our collection and use of the Personal Information, subject to certain exceptions. Please read this section carefully as some rights vary by state.  

• Rights that Require Verification. You may exercise the data subject rights below via our privacy webform or by calling us toll free at (866) 986-9825 and submitting details regarding your request. You may also authorize an agent to make data subject requests on your behalf. In such instances, authorized agents may use the same methods as you to submit the requests on your behalf. To verify your identity and protect your Personal Information, we may ask the requestor to provide information that will enable us to verify your identity in order to comply with your data subject request, such as asking your agent to provide proof of signed permission from you, or asking you to confirm with us directly that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law. 

• Right to Know: You have the right to know the following details about our privacy practices at or before the point of collection. We have provided such information in this Supplemental Policy. You may also request that we provide you with information about the following aspects of how we have handled your Personal Information specifically in the twelve months preceding your request: 

• The categories of Personal Information we have collected about you; 

• The categories of sources from which we collected such Personal Information; 

• The business or commercial purpose for collecting, Selling, or Sharing Personal Information about you; 

• The categories of Personal Information about you that we disclosed and the categories of Third Parties to whom we disclosed such Personal Information;  

• The categories of Personal Information about you that we Sold, Shared, or used for Targeted Advertising purposes, and the categories of Third Parties with whom we Sold or Shared such Personal Information;  

• If we collect Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is Sold or Shared; and 

• The length of time we intend to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period. 

• Right to Deletion: You may request that we delete any Personal Information about you we that we collected from or about you, depending on your state of residence. 

• Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.  

• Right to Access Specific Pieces of Personal Information and Data Portability: You may ask to obtain the specific pieces of Personal Information we have collected about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Information to another entity without hindrance. You may not exercise this right more than two times in a calendar year.  

• Rights that Do Not Require Verification.
  
  
• Right to Opt-Out of the Sale, Sharing, and Use of Your Personal Information for Targeted Advertising: You have the right to opt out of the Sale, Sharing, and use of your Personal Information for Targeted Advertising purposes. You can opt out of the Sale, Sharing, and processing for Targeted Advertising of your Personal Information by clicking here and then clicking “Reject All.” 

• Opt-Out Preference Signals. We recognize opt-out preference signals that we are required to recognize for compliance with applicable law. Where required by U.S. Privacy Laws, we treat such opt-out preference signals as a valid request to opt-out of Sale, Sharing, and processing for purposes of Targeted Advertising, as applicable, for the browser or device through which the signal is sent and any consumer profile we have associated with that browser or device, including pseudonymous profiles. Further, if we know the identity of the consumer from the opt-out preference signal, we will also treat the opt-out preference signal as a valid request to opt out of Sale and Sharing for such consumer. Consumers may use opt-out preference signals by downloading or otherwise activating them for use on supported browsers and setting them to send opt-out preference signals to websites they visit. Please note, however, that our websites do not currently respond to the “Do Not Track” signal. 

• Non-Discrimination. We will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services to you, charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights. 

• Appeals. Residents of certain states have the right to appeal our decisions on their data subject requests. To appeal our decision on your data subject requests, you may contact us at info@tradewater.us (Subject Line: “Data Collection Officer”). Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law. 

H. Other Disclosures

• Residents Under Age 18. If you are under the age of 18 and a registered user of our website, you may ask us to remove content or data that you have posted to the website by writing to info@tradewater.us (Subject Line: “Data Collection Officer”). Please note that your request does not ensure complete or comprehensive removal of the content or data as, for example, some of your content or data may have been reposted by another user. 

• Disclosure for California Residents 
  
  
• Direct Marketing. California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of Personal Information to other entities for their direct marketing purposes in the preceding calendar year. We do not disclose to third parties for their own marketing purposes the categories of Personal Information listed in California’s “Shine the Light” law, such as names, addresses, email addresses, and telephone numbers.
  
  
• Financial Incentives for California Residents. We do not provide financial incentives to California residents who allow us to collect, retain, Sell, or Share their Personal Information. We will describe such programs to you if and when we offer them to you. 

I. This Policy May Change

We are continually improving and adding to the features and functionality of our Services. As a result of these changes or changes in the law, we reserve the right to amend or revise this Supplemental Policy in our discretion from time to time. When we make material changes to this Supplemental Policy, we will notify you by posting an updated Supplemental Policy on our website and listing the effective date of such updates, and by providing any additional notice as required by applicable law. 

J. Contact Us

If you have any questions regarding this Supplemental Policy, you may contact us by using our contact form here, by emailing us at info@tradewater.us (Subject Line: “Data Collection Officer”), or by mailing us at the following address: 

Tradewater, LLC 

Attn: Data Collection Officer 

1016 W Jackson Blvd., #1007 

Chicago, IL 60607