Privacy Policy

Holdings, LLC (“DRAFT,” the “Company,” “we,” or “us”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you and our practices for collecting, maintaining, protecting, using, and disclosing that information.

This policy applies to personal information that we collect:

• Through our Website and any desktop or mobile applications or other mechanisms we provide to connect to our Website functionality (collectively, the “Service”).

• In email, text, chat, and other electronic messages between you and DRAFT.

• In person (including at our brick-and-mortar locations), over the phone, in writing, or through the mail.

• When you interact with our advertising and applications on/through third-party websites and services (if those applications or advertising include links to this policy).

It does not apply to personal information collected by:

• Any third party (such as social media platforms), which includes through any third-party application or content, (for example, advertising) that may link to or be accessible from or on the Service.

• Us pertaining to employees, job applicants, or independent contractors located outside of California.

• Us about entities or individuals with whom we only have a business-to-business (“B2B”) relationship and who are located outside of California.

• By our franchisees, if they collect your personal information through any method for their own purposes.

Please read this policy to carefully understand our policies regarding our collection, treatment, and use of your personal information. If you do not agree with our policies and practices, you should not use our Service. By accessing or using the Service, you accept and agree to be bound and abide by this Privacy Policy and our Terms of Use. You should periodically review this Privacy Policy because it may change from time to time. By continuing to use the Service, you agree to be bound by such changes.

Information we may collect about you

We collect several types of information from and about users of our Service, including information:

• That personally identifies you in particular, or 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 (“personal information”), such as name, mailing address, email address, telephone number, employer, and job title. Personal information also includes “sensitive personal information” which is described later in the policy, but does not include publicly available information from government records or deidentified or aggregated consumer information.

• That is about you but (individually) does not identify you.

• Your payment information, when you make a purchase or place an order through our Service or at one of our brick-and-mortar locations.

• About your internet connection, the equipment you use to access our Service, and usage details (such as the pages of the Service you visit, the time of your visit, and the time spent on those pages).

• About your location when you access and use our Service.

How we collect information

We collect this information:

• Directly from you (for example, from forms you complete or products and services that you purchase).

• Automatically as you navigate through the Service. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

• When you enable location services on your device.

• From our franchisees.

Information you provide to us

The personal information you provide to us may include:

• Information that you provide by filling in forms in our Service. This includes information provided at the time of registering to use our Service, subscribing to our newsletters and communications, posting material, or requesting further services or additional information. We may also ask you for information when you enter a contest or promotion sponsored by us and when you report a problem with our Service. Personal information you provide directly to us may include:

  • First and last name

  • Email address

  • Phone number

  • Address

  • Username and password

• Records and copies of your correspondence (including name, email addresses, or other contact information) if you contact us.

• Your responses to surveys that we may ask you to complete for research purposes.

• Details of transactions you carry out though our Service and at our brick-and-mortar stores for the fulfillment of your orders. You may also be required to provide payment information before placing an order through our Service.

• Your search queries on the Service.

You may also provide information to be published or displayed (“posted”) on public areas of the Service or transmitted to other users of the Service or third parties (“user contributions”). Your user contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users on the Service with whom you may choose to share your user contributions. Therefore, we cannot and do not guarantee that your user contributions will not be viewed by unauthorized persons.

Information we collect through automatic data collection technologies

As you navigate and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Service, including traffic data (including the site you access the Service from), location data, logs, and other communication data and the resources that you access and use on the Service.

• Information about your device (including any mobile device), computer, and internet connection, including model, brand, device date, IP address, operating system, mobile network, and browser type.

The information we collect automatically includes personal information. It helps us improve our Service and deliver a better more personalized service to you by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Service according to your individual interest.

• Speed up your searches.

• Recognize you when you return to our Service.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Service. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Service.

• Flash cookies. Certain features of our Service may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Service. Flash cookies are not managed by the same browser settings as are used for browser cookies.

• Web beacons. Pages of the Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

• Advertising and marketing pixels. We use advertising and marketing pixels for remarketing and conversion tracking purposes. The specific pixels and/or tags that we may use include but are not necessarily limited to: Meta/Facebook Ads Pixel, Google Ads Tag, and Bing Ads Tag.

• Session replay tools. We may use session replay tools to better understand our users’ needs and to optimize this service and experience. Session replay helps us better understand our users’ experience, including how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc. Some session replay tools may allow us to visually represent where users click, move, and scroll on our Service. This type of technology enables us to build and maintain our Service with user feedback. Session replay tools may use cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address, device screen size, device type (unique device identifiers), browser information, geographic location, and the preferred language used to display our website.

• Google Analytics. We use Google Analytics to optimize our Service based on the traffic we receive and assist with marketing. To learn more about Google Analytics, including options for opting out and/or managing the ads you may see online please visit: google.com/policies/privacy/partners. Additional information regarding online advertising is available at: https://www.networkadvertising.org/understanding-online-advertising/what-are-my-options. To learn more about targeted advertising and the choices available to you, visit Webchoices: Digital Advertising Alliance’s Consumer Choice Tool for Web US.

Categories of personal information collected in the past 12 months

The tables below show the categories of personal information and sensitive personal information that we have collected in the past 12 months. Please note that while examples are listed for each category, we do not necessarily collect each of those examples listed.

In the course of providing our products, services, or our Service to you, we may collect certain sensitive personal information about you. In the past 12 months we have collected the categories of sensitive personal information shown in the table below.