This Privacy Policy (this “Policy”) for Position for Growth LLC (doing business as PFG Marketing), a New Jersey limited liability company (“we”, “us”, or “our”), describes how and why we might access, collect, store, use, and/or share (“process”) your personal information (“PI”) when you use our platforms and services. This includes, without limitation, when you visit our websites https://pfg-marketing.com and https://pfg-promos.com, make purchases through our online store, use our e-commerce offerings, or engage with us in other related sales, marketing, or event activities (collectively, the “Services”). Reading this Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your PI is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns regarding this Policy or our processing of your PI, please refer to the contact information set forth in Section 10.

1. Information We Collect. 
1. Information You Provide to Us. We collect PI that you voluntarily provide to us when you register for the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. The PI we collect may include the following: debit/credit card numbers, billing addresses, contact or authentication data, contact preferences, passwords, usernames, mailing addresses, email addresses, phone numbers, and names. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. We do not process sensitive information. All PI that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such PI.
2. Information Collected Automatically. We may automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
3. Children’s Privacy. We comply with the requirements of the Children’s Online Privacy Protection Act of 1998, as amended (COPPA), and the rules promulgated thereunder by the U.S. Federal Trade Commission. We do not knowingly collect PI from children under the age of 13. Our websites, products, and services are directed to individuals who are at least 13 years of age or older. If we become aware that we have collected PI from a child under the age of 13, we will promptly delete such information from our records.
2. Processing of Your Information.We process your PI for a variety of reasons, depending on how you interact with our Services, including to facilitate account creation and authentication and otherwise manage user accounts, to respond to user inquiries/offer support to users, to send administrative information to you, to fulfill and manage your orders, to request feedback, to contact you about your use of our Services, to send you marketing and promotional communications, to evaluate and improve our Services, products, marketing, and your experience, and to identify usage trends. We may also process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
3. Sharing of Your PI.We may share or transfer your information (a) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company; (b) with any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us (collectively, the “Affiliates”), in which case we will require our Affiliates to honor this Policy; and (c) with our business partners to offer you certain products, services, or promotions.
4. Tracking. We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
5. Retention of Your Information.We will retain your PI only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law (for example, to comply with tax, accounting, or other legal obligations).
6. Protection of Your Information.We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any PI we process. We offer the use of a secure server. All sensitive and payment-related information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our database, where it is accessible only to individuals with authorized special access rights to our systems who are required to keep such information confidential. In addition, we follow the standards set forth by the Payment Card Industry Data Security Standard (PCI DSS) to the extent applicable to our processing of payment card information. Despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Accordingly, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will be unable to defeat our security measures and improperly collect, access, steal, or modify your information. Although we will do our best to protect your PI, transmission of PI to and from our Services is at your own risk. You should only access the Services within a secure environment.
7. Your Privacy Rights. You have certain rights in relation to your PI. These rights include, among others:
1. Withdrawing your consent: If we are relying on your consent to process your PI, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in Section 10 below or updating your preferences. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your PI conducted in reliance on lawful processing grounds other than consent.
2. Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by following the opt-out instructions included in those communications or by contacting us using the details provided in Section 10. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
3. Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
4. Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
8. Controls For Do-Not-Track Features.Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy. California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
9. Privacy Rights Specific to United States Residents. 
1. State-Specific Consumer Rights. If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the PI we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your PI. You may also have the right to withdraw your consent to our processing of your PI. We may use your PI for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your PI.
2. Additional State Law Rights. You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include the right to know whether or not we are processing your personal data, the right to access your personal data, the right to correct inaccuracies in your personal data, the right to request the deletion of your personal data, the right to obtain a copy of the personal data you previously shared with us, the right to non-discrimination for exercising your rights, the right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), and the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (profiling). Depending upon the state where you live, you may also have the right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota), the right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland), the right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon), the right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota), the right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California), the right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida). To exercise these rights, you may submit a request using the contact information provided in Section 10 below. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use PI provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
3. California Disclosure.California Civil Code Section 1798.83, also known as the Shine The Light law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of PI (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared PI in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in Section 10.
10. Updates.We may update this Policy from time to time. The updated version will be indicated by a revised date at the top of this Policy. If we make material changes to this Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Policy frequently to be informed of how we are protecting your information.
11. Contact Us.If you have questions or comments about this Policy, you may call us at +1 (973) 462-7008, email us at jmaggio@pfg-marketing.com, or contact us by mail at: Position for Growth LLC, 440 Cornelia Street, Boonton, New Jersey 07005, United States.