“ FlagTools” Privacy Statement

Effective January 1, 2025

This Privacy Statement applies to your interaction with “ FlagTools” as a prospective, current, or former “ FlagTools” customer, visitor, or business partner. It describes how “ FlagTools” collects, uses, shares, and protects personal information from and about you, along with choices you can make about such information. This Privacy Statement is not a contract and does not create any legal rights or obligations.

What Information We Collect

We collect the following categories of personal information in order to provide products and services to you, to communicate with you, to enhance our products, services, and operations, and for other operational, legal, and compliance purposes:

• Identification information that can be used to identify you, such as your name, alias, address, phone number, email address, payment information, login and access credentials, signatures, or other identifiers. We may also collect online identifiers, such as your IP address when you browse our websites or use our applications.
• Commercial information, such as products or services you purchased or considered purchasing, information about your participation in contests, sweepstakes, or promotions.
• Online activities information, such as browsing history, search history, and other information when you interact with our websites, applications, and advertisements, such as keystroke activity.
• Geolocation data, including precise geolocation data if you allow our application to collect it for purposes such as helping you locate the nearest “ Flag Tools ” store or alerting our stores when you are on the way to pick up your orders, in connection with specific services we may offer (such as store map), or for analytic purposes.
• Professional or employment-related information, such as information about you as representatives of our customers and business partners, in connection with our services and the operation of our business, including business contact information, job title, company name, and office visitor access information, where applicable.
• Protected class information under state or federal laws, such as age, gender, and family status.
• Education information, such as when you respond to a customer survey.
• Inferences or preferences we learn or infer about you.
• Sensitive Personal Information, such as precise geolocation, race and ethnicity, government identification, and payment card information, as permitted by law. For example, with your consent, we use precise geolocation to calculate when your order will be delivered so that you will have it ready when it arrives. We may collect government-issued identification for certain types of transactions, such as returns without a receipt.
• Other personal information, if it identifies, relates to, and can reasonably be associated or linked with you (or your household), such as photo data you upload.

Note that we may de-identify or pseudonymize personal information so that it is non-personal information, such as aggregating (combining it with data about other individuals) and/or converting it to a code, sometimes using a function commonly known as “hashing,” or otherwise removing characteristics that make the data personally identifiable to you. We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat de-identified or pseudonymized information as non-personal information to the fullest extent allowed by applicable law. If we combine non-personal information with personal information, then we will treat the combined information as personal information under this Privacy Statement.

We do not knowingly collect or disclose personal information from children under the age of 16 without parental or guardian consent. If a child under the age of 16 has provided us with personal information, we ask that a parent or guardian contact us so that the information can be deleted.

For more information about how we retain your information, please see the “How We Retain Your Information” section below.

What Are the Sources of Your Information

We collect different types of information about you from a number of sources, including information you provide to us, information we automatically collect, information we obtain from other sources (specified below), and information we derive or infer about you.

Information You Provide 

You may choose to provide us with information when you interact with us. Examples include:

• Identification information. You may provide your contact information in case we need to reach out to you. You may also set up your login and access credentials when creating or accessing your “ FlagTools” online account. To complete transactions, we collect your payment information. We may need your government-issued ID information or date of birth for certain transactions such as returns without receipt. When you participate in the chat feature, “ FlagTools” generally does not retain personal information unless you provide your personal information in connection with a transaction, in which case “ FlagTools” may record, use, and retain the data to fulfill your request. If you do not consent, please do not continue with chat assistance.
• Commercial information. You may provide or generate commercial information regarding your “ FlagTools” purchases, returns, exchanges, warranties, and rebates.
• Audio, electronic, video, or image information. You may provide audio, video, or photo to us, such as uploading a photo about your home improvement project or submitting a claim.
• Protected class information under state or federal law. For example, you may provide your protected demographic information, including age, gender, race and ethnicity, and marriage and family status, when you complete a survey from us.
• Sensitive Personal Information. We may collect government-issued identification in certain types of transactions to verify your identity and for fraud prevention purposes, such as when you return a product, request a military discount, or request a membership discount.
• Your preferences and inferences. You may let us know your preferences in a survey, contest, promotion, sweepstakes, or any other content you submit, such as product reviews.
• Professional or employment-related information. You may also provide other professional or employment-related information when you respond to our surveys.
• Education information. You may provide educational information in surveys.
• Other personal information. such as your medical and insurance information, if you submit a claim to us.

Information We Collect by Automated Means 

We collect information by automated means, both online and offline. When you use our websites or mobile applications, “ FlagTools ” and our partners may collect certain information by using Cookies and Other Technologies.

As described under the “What Information We Collect” section, through automated means, we collect geolocation data, commercial information, audio, electronic, video, or image information, online activities, and identification information (e.g., your IP address, device ID, cookie ID, mobile advertising identifier or pixel identifier).

Information We Collect from Other Sources

• Identification information. We may collect your contact information from “ FlagTools ” affiliates, acquired businesses, business partners, public sources or other individuals, such as if someone purchases a product and asks that it be delivered to you.
• Commercial information. We may obtain business information about you, such as your purchase history, from “ FlagTools ” affiliates, acquired businesses, or business partners. If you have a primary address saved in your “ FlagTools ” online account, we may obtain and display publicly available information about your shipping address to help you complete your purchase more easily.
• Inferences or preference information about you, protected class information under state or federal laws, sensitive personal information, professional or employment-related information, education background, and geolocation information. We may collect inferences or preference information about you from business partners, such as data suppliers and data analytics, survey vendors, and public sources, such as information you submit in a public forum (e.g., a customer review).

Information We Generate or Derive

• Inferences or preference information about you. We may generate or derive some information about you through manual or automated means based on other information we collect. For instance, we may analyze your information and infer your shopping preferences to provide tailored recommendations to you. We may connect information we collect about you from the means described above if we can identify you as a “ FlagTools ” customer so that we can provide a personalized experience regardless of how you interact with us.

Why We Collect Your Information

We use your personal information for various business or commercial purposes, including fulfilling products and services, communicating with you, supporting and enhancing our business functions, and for other legal, compliance, and security purposes. In addition to the below, we may use your personal information for other purposes as disclosed at the time of collection or with your consent.

Fulfill Products, Services, and Transactions

We may use your identification information, commercial information, online activities, geolocation information, audio/video, geolocation, sensitive personal information, and other personal information to provide products and services to you, such as:

• Provide and deliver products and services, fulfill your orders and transactions, and manage returns and exchanges
• Process, record, and track your purchases, payments, returns, warranties, and rebates
• Process payment
• Create and manage your account registrations or benefit or reward program enrollment
• Conduct and administer contests, surveys, and sweepstakes
• Provide you with in-store navigation and mapping services and help you find store locations near you
• Fulfill benefits associated with your membership or other use of our products and services
• Identify and verify your identity when needed to provide you with products and services or access to our systems

Facilitate Customer Communication and Outreach 

We may use all of the categories of information described under the “What Information We Collect” section to facilitate and tailor our outreach to you, such as:

• Communicate with you through various channels with transactional or promotional information, such as transaction confirmation and reminder, newsletters, coupons, and other messages
• Evaluate and respond to your requests, inquiries, and applications
• Administer programs for product reviews and surveys as submitted by you and other customers

Enhance Our Products, Services, and Operations

We may use all of the categories of information described under the “What Information We Collect” section to enhance our products, services, and operations, such as:

• Conduct research and internal analytics, develop new products and services, perform market research and data analytics, and analyze our products, services, websites, and applications
• Customize your experiences in our stores and online, including personalized advertisements and offers
• Determine and manage the effectiveness of our advertising and marketing
• Administering our websites and applications, and performing accounting, auditing, billing, reconciliation, and collection activities

Comply with Legal, Compliance, Law Enforcement, and Security Requirements

We may use identification information, commercial information, online activities, geolocation, and audio, electronic, video, image, and other personal information for legal, compliance, fraud prevention, and security purposes, such as:

• Comply with and enforce applicable legal requirements, industry standards, and our policies and terms, such as our Terms and Conditions of Use
• Assist law enforcement, respond to regulatory inquiries, and defend our or any third party’s rights or property
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity

How We Share Your Information

We share your personal information with unaffiliated entities (companies outside the FlagTools’s family) with your consent. Specifically, we share your personal information to conduct business with service providers and business partners, third parties to whom you agree or direct us to share your personal information, comply with legal requirements, and transfer our business.

Product or Service Providers

We may disclose your personal information to companies that provide various services to us in areas, such as installation, repair, warranty, order processing and fulfillment, information technology, marketing, customer service, data analytics, research and enhancement, fraud prevention, and legal, compliance and risk management. If you purchase a product sold by one of our third-party providers, we may share your personal information with them for purposes such as processing and fulfilling your purchase. We may also disclose your personal information to product suppliers for purposes such as post-sale services or recalls. These companies need access to information about you in order to perform their functions and are not authorized to use the information for any other purpose.

Notwithstanding anything else in this policy, “ FlagTools ” does not share personal data we collect specific to our SMS/MMS/RCS text message programs (such as mobile number and record of consent) with unaffiliated third parties for their own direct marketing purposes without your consent.

Third-Party Business Partners

We may disclose information about you to unaffiliated third parties for their own specific purposes. For instance, we may provide your information to a vendor that offers additional product warranty coverage, to a business partner who jointly provides or promotes a product or service to you, to a loyalty program partner that offers additional benefits to you, or to a social media or online advertising technology company to serve targeted advertising about products and services available at “ FlagTools ” to you.

Third Parties to Whom You Agree or Direct Us to Share Your Personal Information

We may share your personal information when you expressly consent or otherwise direct us to do so. For example, you may agree to share your information with a third-party content provider in order to have access to that content.

Legal, Enforcement, Security and Investigation

We may disclose information about you (1) if we believe we are required to do so by law, regulation, or legal process, such as a court order or subpoena; (2) as we deem appropriate or necessary in response to requests by government agencies, such as law enforcement authorities or tax authorities; (3) when we believe disclosure is appropriate or necessary to protect the rights, property or safety of “ FlagTools ”, our customers or others, including to prevent physical, financial or other harm, injury or loss or to collect the debt you owe; or (4) for fraud or in connection with an investigation of suspected or actual unlawful activity.

Sale or Transfer of Business or Assets

We reserve the right to transfer personal information we have about you (including, without limitation, during the course of any due diligence process) if we sell or transfer all or a portion of our business or assets (including, without limitation, in the event of a reorganization, dissolution, bankruptcy or liquidation).

Categories of Personal Information Disclosed for Business Purposes

We disclose all of the categories of personal information described under the “What Information We Collect” section for business purposes, including fulfilling products, services, and transactions, facilitating customer communication and outreach, enhancing our products, services, and operations, and complying with legal, compliance, law enforcement, and security requirements. Examples of the types of vendors we disclose personal information to for these purposes include analytics and research vendors, installation, repair,r, and warranty services companies, order processing and fulfillment vendors, security and fraud prevention, legal, compliance, and risk management vendors, information technology vendors, financial institutions, and marketing and advertising vendors.

Your Privacy Rights and Choices

Privacy Rights for Residents of Certain States in Certain Countries

Residents of certain states in the United States, for example, have the right to access, delete, correct, or opt out of certain types of processing or sharing of personal information. Depending on the state in which you live, and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

Access your personal information. 

You may request confirmation of the processing of your data and access a copy of the personal information we maintain about you. In certain states, to the extent feasible, the data will be provided in a readily usable format to allow data portability.

In addition, in California, you may request to learn more about the categories and specific pieces of personal information we collect about you, the categories of sources from which personal information is collected, and the categories of entities with whom we share personal information. You can also learn about categories of entities who may use your personal information for additional purposes relevant to our products or services (e.g., joint marketing, joint product/services offering) for valuable considerations. The information may be delivered by mail or electronically at your request.

In Oregon, you may request to learn more about the specific third parties to which we disclose personal information.

In Delaware, you may request a list of the categories of third parties with whom we have specifically shared your personal information.

Correct your personal information.

You may request to correct the inaccurate personal information we maintain about you. If you would like to change information related to your order or services, please contact a store associate or “ FlagTools ” Customer Care.

Delete your personal information.

You may request that “ FlagTools ” delete the personal information we maintain about you subject to certain exceptions permitted by law such as to complete the transactions, detect security incidents, prevent fraudulent or illegal activities, identify and repair errors, comply with laws and regulations, and for other solely internal and lawful purposes. If you make a deletion request, all of your information (including your account and associated points, rewards, and benefits) will be deleted. We cannot restore your account if you change your mind.

Opt out from the sale of your personal information, and sharing for cross-context behavioral advertising, and targeted advertising.

You may opt out of the sale of your information (which includes the exchange of your personal data for valuable consideration), sharing, and targeted advertising.

Sensitive personal information. 

To the extent we collect and process “sensitive personal information,” we obtain opt-in consent as required by applicable law. Residents of certain states may request “ FlagTools ” to limit the use and disclosure of sensitive personal information for certain purposes permissible by law, such as providing products or services, detecting security incidents and protecting safety, preventing fraud or illegal actions, and maintaining the quality of services we provide. Please note that the definition of sensitive personal information varies by state, so your rights with respect to specific types of information will depend on your state of residency.

Opt out of profiling in furtherance of legal or similarly significant effects.

“ FlagTools ” does not process personal information for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects and therefore does not provide this right to residents in applicable states.

Non-discrimination for the exercise of privacy rights. 

We will not discriminate or retaliate against you for exercising your rights under relevant state privacy laws.

Appeal your request.

Residents of certain states may appeal a decision to not take action on your privacy rights request within a reasonable time after your receipt of the decision.

Below is a summary of your privacy rights based on your state of residency:

• California Residents: Right of access, correct or delete personal information, right to opt out of “sale” and “sharing” of personal information for targeted advertising, limit the use and disclosure of sensitive personal information, and non-discrimination.
• Colorado, Connecticut, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Virginia, Montana, Oregon, and Texas Residents: Right of access, correct or delete your personal information, right to opt out of the sale of personal information and targeted advertising, right to opt out of profiling, no discrimination, right to appeal.
• Utah Residents: Right to access or delete personal information, right to opt out of sale of personal information and targeted advertising, no discrimination.

How to Submit Privacy Request(s)

Depending on the state you reside in, you have certain rights as indicated below. “ FlagTools ”provides the right to access and the right to opt out of sale/sharing and targeted advertising to residents of all states.

Access, Correction, or Deletion of Personal Information.

• To access, correct, or delete your personal information, please go to the “ FlagTools ” Privacy Request Portal or send an email. We need your contact information, such as name, address, phone number, and email, in order to submit your request and verify your identity for access or deletion requests.
• Our verification process includes you correctly answering a series of questions to verify your identity. We may collect your language preference in order to present you with identity verification questions in your preferred language. Your language preference information will not be used for any other purpose and will be deleted after your request is completed. We may ask you to log into your “ FlagTools ” online account (if you have one) or send a text message to your mobile phone number to verify your identity with your consent.

Opt out from sales, and sharing for cross-contextual behavioral advertising and targeted advertising.

To opt out of the sale, sharing, and targeted advertising, please submit an opt-out request through the “ FlagTools ” Privacy Request Portal or send an email and request a restriction on the sale, sharing, or targeted advertising.

Cookie-based opt-outs.

To disable sharing through cookies set by third parties for advertising and analytics purposes adjust your cookie preference for “ FlagTools ” sites. The opt-out is associated with the browser that you use to set those preferences unless we know you are browsing our site. Please also review the “Interest Based or Other Targeted Advertising” section below for information on industry tools and device settings that may be available to you.

Global Privacy Control (GPC) and Do Not Track (DNT). 

GPC and DNT are offered by some web browsers and are settings that automatically inform websites of your privacy preferences. When you choose to turn on the GPC/DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and/or other web services you encounter while browsing to exercise your privacy rights and stop tracking your activity. You can learn more about and set up GPC here: https://globalprivacycontrol.org/#about and set up Do Not Track here: http://www.allaboutdnt.com. We comply with GPC as required under applicable law, but because there is not yet an accepted standard for how to respond to browser DNT signals, we do not currently respond to them.

Nevada Residents. Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain “covered information” that a website operator has collected or will collect about the resident. While we do not currently sell “covered information” as defined under Nevada law, if you reside in Nevada, you have the right to submit a request to Official@flagtools.com to opt out of the future sale of covered information. Please include “Nevada Rights Request” in the subject line.

Limiting Use and Disclosure of Sensitive Personal Information. As described above, certain personal information we collect may be considered sensitive information under California law. To limit the use and disclosure of sensitive personal information, please submit a request to limit the use and disclosure of sensitive personal information through the “ FlagTools ” Privacy Request Portal or email us at Official@flagtools.com.

Appeal. To appeal a decision to not take action on your privacy right request, please click the “Your Open Request” tab in the “ FlagTools ” Privacy Request Portal, or send an email to Official@flagtools.com.

Authorized agent. California residents may designate an agent to submit privacy requests on your behalf, but for your protection, we may need to verify your identity directly with you before fulfilling certain requests, and we will deliver your personal information directly to you (if requested). We need your agent’s contact information, and your agent needs to have your information ready when submitting the request.

If you are an authorized agent submitting a request to opt out of sales or targeted advertising on behalf of a Colorado, Connecticut, Delaware, Iowa, Oregon, Montana, Nebraska, New Hampshire, New Jersey, or Texas resident, please submit the request pursuant to the above instructions. We may require documentation to authenticate the customer’s identity and that you are authorized to submit the request on the customer’s behalf in order to be able to fulfill your request. Please keep in mind that if we cannot authenticate that you are authorized to act on the customer’s behalf or we cannot authenticate the customer’s identity, we may deny the request.

We respond to requests to exercise privacy rights in accordance with our legal obligations in different countries and regions, but please note that these rights are based on residence, and not all of these rights may apply to you depending on where you live. In some cases, we may deny a privacy request, such as if we cannot verify your identity.

How We Protect Your Information

We maintain administrative, technical, and physical safeguards designed and intended to protect personal information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Despite these safeguards, due to inherent uncertainty in the use of the internet and information systems and the potential for unlawful attacks by third parties, we cannot guarantee that the use of our systems, websites, or applications will be completely safe or secure.

How We Retain Your Information

We retain personal information only for as long as is reasonably necessary to fulfill the purpose for which it was collected, comply with our legal and contractual obligations, resolve disputes, and enforce our agreements. To determine the appropriate duration of the retention of personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or de-identify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will store and protect the personal information until deletion or deidentification is possible.

Other Important Considerations

Do Not Track

We do not process or respond to “Do Not Track” signals from your browser that enable customer choice regarding the collection of personal information about one’s online activities over time and across third-party websites or online services. For more information about how we respond to other opt-out preference signals such as the Global Privacy Control, please refer to the “How to Submit Privacy Request(s)” section above.

Cookies and Other Technologies

Cookies refer to small packets of data that websites send to your computer or other internet-connected devices. “ FlagTools ” and our business partners use them for different purposes. These technologies can uniquely identify your browser and log information, such as your device type, system and browser information, IP address, system language, location, and your interactions with the site. Like other websites, we need some essential cookies for our website to function properly. We also use some functional cookies to pre-populate your log-in ID to make it easier for you or to help us remember where you left off when you shopped, so you do not have to restart all over again. We may use browser cookies, flash cookies, and other types of local storage.

We and our third-party partners may record your keystroke activity and rhythms, mouse movements, scrolling, and clicks when you use our websites or mobile applications for our internal business purposes, such as for website analytics, to improve our products and services, and to address functionality issues.

An embedded script is programming code that is designed to collect data about your interactions with the Services, such as the links you click on. The code is temporarily used by our server or a third-party service provider or business partner while you browse or interact with our services and is deactivated or deleted when you disconnect from our services.

We use embedded scripts and the tools provided in Software Development Kits (“SDKs”) to collect data through mobile devices such as the hardware model, operating system and version, identification numbers assigned to your mobile device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network data, and website usage behavior. SDKs are software packages that contain a set of tools that can be used to help build applications and implement new features in existing apps including those that collect data from your device.

“ FlagTools ” and our business partners also use cookies with other technologies, such as web tags, beacons, or pixels. They allow us to count visitors to our web pages, evaluate the effectiveness of our promotional campaigns, or recommend relevant products and services to you when you browse social media or other websites. We think these technologies create meaningful interactions with you and are helpful, but you can let us know that you prefer otherwise by opting out from these advertising cookies and technologies by clicking below. You can find more information and options in the Interest-Based Advertising and Other Targeted Advertising section. We may also use third-party web analytics services in our online services to help us analyze how users use our online services.

Interest-Based Advertising and Other Targeted Advertising

We collect data about your activities on our websites and applications for use in providing tailored advertising, and we may share information about activities on our websites with advertising networks administered by third parties. These ad networks track your online activities over time and across websites by collecting information through automated means, and they use this information to show you advertisements that are tailored to your individual interests. As a result, you may see certain ads on other websites based on prior activities on our websites and vice versa. We may also combine information about your online activities with your activity in a “ FlagTools ” store using our mobile applications.

We may also utilize third-party services that may allow us to associate your prior “ FlagTools ” online or in-store transaction data, operating system, user-agent string, IP address, internet browser, installed fonts, and similar information with a pseudonymized ID, which can then be used to target “ FlagTools ” advertising to you on other websites and online platforms.

To provide you with a consistent shopping experience, we may also associate various devices you utilize (e.g., smartphones, tablets, and desktop computers) by using the information we collect about you. We may combine information we collect from your devices with other information we have about you, such as your “ FlagTools ” account information, your interaction with our sites, apps, and services, and your transaction history.

Social Media Widgets

Our online services may include social media features (e.g., a Facebook “Like” button). These features are connected to third-party platforms and may allow such third parties to collect certain information, such as your IP address and which pages you visit on our websites. When you interact with these features through our services, we will receive your personal information from the third party and you agree to share data, including personal information, about your interactions with our service with these third parties. We may also receive personal information identifying you if other users of social media give us access to their profiles and you are one of their connections or “friends.” These social media features are not operated by “ FlagTools ”. Personal information collected and stored by the third-party platform is subject to that third party’s privacy practices and is governed by their privacy policy. The third party may allow you to remove the application or feature; however, we may retain data previously collected.

Links to Other Websites and Use of Third-Party Services

Our websites may link to other websites for your convenience and information. For instance, they may link to websites of product suppliers, manufacturers, and service providers. We are not responsible for the content or privacy practices of any website that we do not control and that does not point to this Privacy Statement.

We partner with third parties including delivery services to assist you with your shopping. You may have the opportunity to link your account to your account with that third party. If you choose to do so, that third party will share your personal information with us. Your personal information submitted to the third party is subject to the privacy policy and terms of that respective third party.

How to Contact Us

If you have questions or comments about this Privacy Statement or if you would like us to update the information we have about you or your preferences, please contact us as indicated below.

Privacy Office

No.5, Huaxi 13th Lane, Henggang Street,

Longgang District,

Shenzhen, Guangdong, China

Official@flagtools.com

Updates

This Privacy Statement may be updated periodically and without prior notice to you to reflect changes in our information practices or relevant laws. We will post a notice on Lowes.com and other websites that point to this Privacy Statement to notify you of any substantive changes to the way we collect and use information. We will indicate at the top of the Privacy Statement when it was last updated.