EFFECTIVE OCTOBER 1, 2020

This Privacy Policy explains how Stokkee, LLC, its brands, subsidiaries, and Affiliates (“Stokkee”, “we” or “us”) collect, use, share, and protect personal information. Headquartered in Lansing, Michigan, we provide web hosting solutions including dedicated servers and virtual private servers to our customers (“Services”). Stokkee has data center locations in the US.

Stokkee respects the privacy of every individual who visits www.stokkee.com (“Website”) and/or purchases its Services. This Privacy Policy is our commitment to transparency in communicating how Stokkee collects, uses, and discloses the information that is collected from you, the visitor of its website and/or customer as well as the choices you have with respect to the information.

BY USING OUR SERVICES OR VISITING OUR SITE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THIS POLICY, PLEASE DO NOT USE OUR WEBSITE OR SERVICES OR OTHERWISE PROVIDE US WITH YOUR INFORMATION.

SCOPE OF POLICY

This Privacy Policy applies to how we collect, use, and disclose information from the following individuals:

• Customers – individuals who register, on their own or on behalf of an entity, to use Stokkee Services with the creation or administration of a Stokkee account.

• Event/Marketing Participants – individuals who provide their information to Stokkee when they register for Stokkee webinars, subscribe to marketing material, participate in surveys or contests, or attend other Stokkee events.

• Website Visitors – individuals who visit Stokkee’s Website and opt to provide contact information including an email address to receive communications from Stokkee. For purposes of this Privacy Policy, a Website Visitor does not include an individual who visits a website hosted by Stokkee but owned and operated by a Stokkee customer.

This Privacy Policy does not apply to our Customers' website hosted by Stokkee. Our Customers are responsible for the information they or their end users store in our hosting environment as well as compliance with applicable laws, regulations, and Stokkee’s terms related to the collection and storage of personal information.

INFORMATION WE COLLECT

Customers

Stokkee asks for your account information which includes your name, email address, physical address, phone number, credit card information, and website domain. By voluntarily providing Stokkee with your account information, you represent that you own and consent to our use of such personal data.

Event/Marketing Participants

Stokkee may ask for your name, email address, physical address, and phone number. Participation in events, surveys, contents, or subscribing to marketing material is voluntary and you may choose whether or not to participate and therefore disclose this personal data.

Website Visitors

At your option, Stokkee asks and may collect your name, email address, physical address, and phone number. In addition, we also collect information such as web server logs, internet protocol (IP) addresses, browser type, or other statistical information as part of aggregated data. We use Google Analytics to help us gather statistical information about the visitors to our Website and how they use the Website on an anonymous, aggregate basis. However, we will not associate this data with your personally identifiable data unless required to do so to cooperate with law enforcement activity or other governmental requests or to comply with the law. We may use this information to gain a better understanding of the users of our Website, to improve our Website, and to improve our Services. Depending on the type of browser and device that you use, you may have the ability to control the type of information that Google Analytics uses. To understand how Google Analytics collects and processes data, please visit www.google.com/policies/privacy/partners/.

Stokkee uses cookies, beacons, tags, and other tracking technologies to gather demographic information about you, identify your visits to our Website, and other interactions with our Website, and personalize your search experience on our Website. We gather information such as internet protocol (IP) addresses, internet service provider (ISP), operating system, browser type, and date/time stamp, and store it in log files. See our Cookie Policy, below, for more information.

HOW WE USE YOUR INFORMATION

Stokkee uses the information it collects about you in the following ways:

• To respond to any requests from you regarding sales and support.

• To contact you regarding any agreements or accepted terms that you may have with Stokkee for the Services.

• To provide you with marketing emails, special offers, advertising campaigns, or newsletters.

• To provide you with information logs associated with the use of Stokkee’s Services.

• To contact you regarding functionality changes to our Services or Website.

• To develop new features and functionality for our Services and Website.

• To collect payment and bill for our Services.

• To help personalize searches.

• To diagnose problems.

• To find and prevent fraud.

• To register your domain and IP address through ARIN (American Registry for Internet Numbers).

• To carry out other purposes as disclosed to you through the Website, or found in terms or an agreement between you and Stokkee.

• Process for other purposes for which we obtain your consent.

HOW WE SHARE INFORMATION

Stokkee shares the information it collects about you in the following ways:

• Third-Party Providers - Stokkee may share your information with third-party providers that provide services on our behalf. These companies may assist with marketing support, processing credit card payments, providing sales leads, and customer support. Third-party providers may only process personal information pursuant to Stokkee’s instructions, and in compliance with the Privacy Policy and other applicable regulations (e.g. EU-US Privacy Shield framework).

• Advertising - Based on cookies and other tracking devices, we may work with advertising companies to display ads that may be of interest to you.

• Business Transactions - To provide information to a third party in the event of any disposition of all or any portion of our business (e.g. reorganization, sale, assignment, bankruptcy).

• Aggregated or De-identified Data - We may aggregate or otherwise de-identify your personal information. We own such aggregate or de-identified information and may use and share this information with third parties.

• As Required by Law or Similar Investigations - To comply with legal obligations (e.g. subpoena) or investigate potential legal violations. Stokkee may be required to share personal data in response to lawful requests from public authorities including to meet national security and/or law enforcement requirements.

• Safety - We may disclose your information to protect and defend the safety of Stokkee in connection with investigating and preventing fraud or security issues.

• Consent - Stokkee may share your information with your consent.

COOKIE POLICY

Cookies are not the only way to track visitors to a website. We may use similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enables us to recognize when someone has visited our Websites. These technologies often depend on cookies to function properly, and so disabling cookies may impair their functioning.

Third-Party Cookies. In addition to our own cookies, we collaborate with various third-party service providers who also use cookies to help us optimize our website and understand more about the visitors to our website. For example, we use Google Analytics to provide us with demographic information about our visitors and to help us analyze how people use our website. Our third-party service providers include AffiliateWP, Bing, CartStack, Cloudflare, Facebook, Google Analytics, Google TagManager, HotJar, Hubspot, LinkedIn, OptinMonster, Perfect Audience, and Salesforce. To learn more about how these providers use cookies, please click the links above or visit their respective websites to view their privacy policies.

How Can You Disable Cookies and Other Tracking Technology? Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit All About Cookies and Your Online Choices. Some Internet browsers also may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit All About Do Not Track.

YOUR CHOICES

You may unsubscribe from receiving promotional or marketing emails from Stokkee at any time by using the “unsubscribe” link in the email received, or by emailing us at help@stokkee.com. As outlined in the Section, Information We Collect, you can also control your cookie settings.

With respect to your account information, you may update, correct, or delete information that you provided to us by logging into your Stokkee account or contacting us at help@stokkee.com.

You are not required to provide all personal information identified in this Policy to use our Website or receive our Services, but certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.

DATA RETENTION AND SECURITY

When Stokkee no longer has a legitimate business need (e.g. termination of a Customer agreement) to process your personal information, we will either delete or anonymize it.

Stokkee takes all reasonable steps to protect information received from you from loss, misuse, unauthorized access, disclosure, alteration, and/or destruction. We maintain technical, physical, and administrative safeguards to secure your information, and we use industry-standard encryption for your data that is transferred over the Internet. Despite its use of encryption, Stokkee cannot guarantee any method of transmission of information over the internet is 100% secure. If you have any questions about the security of your personal information, please contact us at help@stokkee.com.

INTERNATIONAL TRANSFERS

Stokkee is a US company that stores your information in its data centers in the United States or, in limited cases, in the Netherlands. Stokkee may transfer your personal information to countries other than the country in which you live. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.

CHILDREN

Our Website and/or Services are not directed at children and our services are designed for businesses. We do not knowingly collect information from or about children under 13 years of age, and the use of our services by children under 13 years of age is forbidden.

THIRD-PARTY SITES AND SERVICES

The Website may contain links to other websites and services operated by third parties. These links are not an endorsement of or representation that we are affiliated with, any third party. We do not control third-party websites, applications, or services, and we are not responsible for their actions. Other websites and services follow different rules regarding their collection, use, and sharing of your personal information. We encourage you to read their privacy policies to learn more.

NOTICE TO EUROPEAN USERS

The following applies to individuals in the European Economic Area (EEA):

Controller. Stokkee, LLC is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

Legal bases for processing. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us using one of the methods detailed at the end of this Privacy Policy.

Retention. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your Rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.

• Correct. Update or correct inaccuracies in your personal information.

• Delete. Delete your personal information.

• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice

• Restrict. Restrict the processing of your personal information.

• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by contacting us as detailed at the end of this Privacy Policy. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator on the EDPB website.

Cross-Border Data Transfers. Any information you provide to us through the use of the Website may be stored, processed, transferred among, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Policy regardless of where your personal information is kept. Regarding transfers from the EEA to the United States, we rely on the derogations for transfers that are necessary to perform the transaction with you. Where required by law, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. If you reside in other non-US jurisdictions outside the EEA, your use of the Website or provision of any personal information constitutes your consent for the transfer of such data to the United States for the purposes identified above. If you have questions about cross-border transfers, please contact us as detailed below.

NOTICE TO CALIFORNIA RESIDENTS

The following section applies to California residents.

Shine the Light. Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes. To make a request please contact us as instructed in the “How to Contact Us” section below and specify you are making a Shine the Light request.

California Consumer Privacy Act (“CCPA”). The CCPA creates consumer privacy rights and requires businesses to make disclosures about their privacy policies and practices. Pursuant to the CCPA, both our privacy practices and your privacy rights are discussed in detail in the following information.

Personal Information We Collect. We collect your personal information when you interact with our Website or otherwise communicate with us. For the purposes of this Privacy Notice, “personal information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. We have collected the following categories of personal information covered by the CCPA from consumers within the past 12 months, and have used it for the following business purposes:

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice.

Sharing Your Information. We do not sell your personal information but may disclose it to third parties for a business purpose. Specifically, in the past 12 months, we have disclosed unique personal identifiers such as online identifiers and IP addresses and Internet or other electronic network activity information to our Internet service providers, operating systems and platforms, and marketing intelligence service providers.

Your Rights. The CCPA gives you certain rights regarding your personal information:

• Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific personal information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).

• Right to Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions.

Exercising Your Rights. To exercise your rights above, please submit a request to us, or email us at help@stokkee.com. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide the following information: name, email address, and the type of request you wish to make. We may ask for additional information to verify your identity. The information you provide in your request and any follow-up information we ask for from you will be used solely to verify your request. After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request. Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information. We may not discriminate against you if you choose to exercise your rights.

Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. We will deliver our written response by mail or electronically, at your option. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable. We will not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.

CHANGES TO PRIVACY POLICY

Stokkee reserves the right to modify this Privacy Policy at any time, however, should we change the Privacy Policy in a material way, a notice will be posted on our website along with the updated Privacy Policy. If you disagree with the changes, you may terminate your Services.

CONTACT US

If you have any questions or concerns over this Privacy Policy or wish to exercise any of your statutory rights, please contact us at: help@stokkee.com