Sturgis TT (“Sturgis TT”, “we”, “us” or “our”) operates the websites and mobile apps where this Privacy Statement is displayed (the sites and apps collectively “STURGISTT.COM”). STURGISTT.COM is a general audience platform and includes websites (including subdomains) and associated applications and digital services (such as mobile and other device applications), and other associated offerings that are owned, offered or operated by or on behalf of Sturgis TT. Sturgis TT’s Privacy Officer can be reached at communications@sturgistt.com. Your privacy is important to us. As such, we provide this Privacy Statement explaining our online information practices and the choices you can make about the way your information is collected and used at STURGISTT.COM. Please be advised that the practices described in this Privacy Statement apply only to information gathered through and in connection with STURGISTT.COM.

The Information We Collect

We receive information about you that you provide to us directly, such as personal information you provide when you visit STURGISTT.COM, and information that is passively or automatically collected from you, such as information collected from your browser or device. In this Privacy Statement, we refer to all of this as the “Information.”

Information You Provide to Us. At STURGISTT.COM, you can register, order products, enter contests, vote in polls or otherwise express an opinion, subscribe to one of our services such as our online newsletters or text message alerts, or participate in one of our online forums or communities. In the course of these various offerings, we often seek to collect from you various forms of Information, such as: name, address, e-mail address, telephone number, and date of birth.

Certain features on STURGISTT.COM also allow you to submit Information about other people. For example, you might submit a person’s name and e-mail address to send an electronic greeting card and, if you order a gift online and want it sent directly to the recipient, you might submit the recipient’s name and address. This Information may include, for instance, a recipient’s name, address, e-mail address, and telephone number.

Information That is Passively or Automatically Collected. We, and our “Partners” which include our third party service providers, advertising networks and platforms, agencies, analytics/reporting vendors, platform and infrastructure monitoring vendors, and cloud service providers use automated means to collect various types of Information about you, your computer or other device used to access STURGISTT.COM. A representative, non-exhaustive list of the types of automatically collected Information may include:

• network or Internet protocol address and type of browser you are using (e.g., Chrome, Safari, Firefox, Internet Explorer)
• the type of operating system you are using (e.g., Microsoft Windows or Mac OS)
• the name of your Internet service provider (e.g., Comcast, Verizon or AT&T) and domains used by such providers
• mobile network
• device identifiers (such as Apple IDFA or an Android Advertising ID)
• device settings and browser settings
• the date and time of your visit to STURGISTT.COM
• which STURGISTT.COM pages you have visited and which sites you visited before and after you visit STURGISTT.COM
• the type of handheld or mobile device you used to view STURGISTT.COM (e.g., iOS, Android)
• the content and advertisements you have accessed, seen, forwarded and/or clicked on.

Please see the Section titled Our Cookie Policy for more information about how the foregoing Information may be collected and used, as well as your choices related to such collection and use.

Information Collected By and From Third Party Platforms. When you engage with our content on or through social media services or other third party platforms (“Third Party Platforms”), plug-ins, integrations or applications, you may choose to allow us to have access to certain Information in your profile. This may include your name, e-mail address, photo, gender, birthday, location, an ID associated with the applicable third party platform or social media account user files, “liked” photos and videos, your list of friends or connections, people you follow and/or who follow you, or your posts or the ‘likes’. For a description of how social media services and other third party platforms, plug-ins, integrations or applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings.

When we interact with you through our content on third party websites, applications, integrations or platforms, we obtain any information regarding your interaction with that content, such as content you have viewed, your game performance, high scores, and information about advertisements within the content you have been shown or may have clicked on.

How We Use the Information We Collect

We, along with our Partners, use your Information for the following legitimate business purposes:

• to communicate with you about STURGISTT.COM, such as to fulfill a request or order by you, or to contact you about your account with us
• to fulfill your requests for our products, programs, and services, including without limitation requests for newsletters and notifications
• to respond to your inquiries and notify you if you have won one of our contests
• to inform you about products, programs or services that we believe may be of interest to you, including those offered by third parties
• to enforce the legal terms (including without limitation this privacy statement and our terms of use) that govern your use of STURGISTT.COM, and/or for the purposes for which you provided the information
• to provide technical support for STURGISTT.COM
• to investigate and prevent fraud or potentially illegal activities (including, without limitation, copyright infringement or fraud related to a contest) on or through STURGISTT.COM
• to protect the safety of our users and the security of our platforms
• to serve you customized or personalized ads, offers and content based on your visits to and/or usage of STURGISTT.COM or other online or mobile websites, applications, platforms or services, and to analyze the performance of those ads, offers and content, as well as your interaction with them
• to perform analysis regarding how you use STURGISTT.COM or any part thereof
• to send gifts, cards, invitations or emails if you use these services, to your designated recipients
• to improve our products, services and STURGISTT.COM
• as otherwise permitted by law or as we may notify you from time to time

When we have your consent to do so, we also use information from your social media account to:

• give you exclusive content
• personalize your online experience with us within and outside our applications or websites
• contact you through the social media service or directly by sending you the latest news, special offerings, and rewards, and
• enable you to share your experience and content via social media services.

From time to time, we enhance the Information we collect from you with other information that we obtain from third party sources.

How We Share and Disclose Your Information

We share or disclose your Information as follows:

• To Partners that we have engaged to perform business-related functions on our behalf. Each such Partner is contractually obligated to provide services to us in a manner consistent with this privacy statement. Our Partners use your Information to provide us with the following services:

• conduct research and analytics
• create content
• provide customer, technical or operational support
• conduct or support marketing (such as email or advertising platforms)
• fulfill orders and user requests
• handle payments
• host STURGISTT.COM, forums and online communities
• administer contests
• maintain databases
• send or support online or mobile advertising, and
• otherwise support STURG

  ISTT.COM.

• In response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency’s request or similar request, or where we believe in our sole discretion that disclosure is legally necessary.
• With third parties in order to investigate, prevent, or take action (in our sole discretion) regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or STURGISTT.COM, or violations of our policies, the law or our Terms of Use, to verify or enforce compliance with the policies governing STURGISTT.COM and applicable laws or as otherwise required or permitted by law or consistent with legal requirements.
• If we, or one of our business units, undergoes a business transition, like a merger, acquisition by another company, or sale of all or part of our assets, or if a substantial portion of our or of a business unit’s assets is sold or merged in this way, we will transfer some or all of your Information as part of that transaction.
• With affiliates, so they can provide, improve and communicate with you about their own, or their marketing partners’, products, platforms, and services.
• We share your email or mailing address with our advertising partners (including e. magazine publishers, retailers, non-profit organizations, and their advertising agencies and marketers) that wish to market their own products or services to you. If you wish to opt out from such sharing, please visit the Opting Out of Marketing Communications section below for further instructions.

Co-Sponsored Content. Please note that STURGISTT.COM may offer content (e.g., contests, sweepstakes, promotions, games, applications, or social network integrations) that is co-sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties may obtain information directly from you when you access such co-sponsored or co-branded content on STURGISTT.COM. We have no control over these third parties’ use of this information, which is subject to their own privacy policies.

Public Posts. If you choose to submit Information or content for public distribution or publication (e.g., a letter to our editors, comments sent to our writers and/or personalities, a posting to a blog or a discussion board, or a video), we may publish that Information and content, along with other Information about you (such as your name, screen name or location). Likewise, if you register and create a profile with STURGISTT.COM, the screen name you select, as well as other content you submit or upload to your profile page (e.g., photos, comments, video, reviews), will be displayed publicly on STURGISTT.COM, is searchable, can be found by third parties and may be reused and redistributed by us in our sole discretion. See our Terms of Use for details on our use of content you submit.

How Long Do We Retain Your Information?

We retain your Information for the period necessary to fulfill the legitimate business purposes or uses outlined in this Privacy Statement, unless a longer retention period is required or allowed by applicable data protection law or to otherwise fulfill a legal obligation.

Our Cookie Policy

We and our Partners use cookies and other common tracking technologies both to provide our services to you and to serve customized advertising to you. We may also work with Partners to help them advertise to you when you visit other websites or mobile applications, and to help them perform user analytics. These technologies may also be used to analyze how our users interact with advertising on STURGISTT.COM and elsewhere, and more generally, to learn more about our users and what services or offers you might prefer to receive. We describe some of these technologies below, as well as your choices related to these tracking technologies.

Cookies. We use “cookies”, “web beacons” or other common tracking technologies. Cookies are text files placed in your computer’s browser to store your preferences.

We, and our third party service providers, advertisers, advertising networks and platforms, agencies, or Partners, use cookies or other common tracking technologies to understand site and Internet usage and to improve or customize the products, content, offerings, services or advertisements on STURGISTT.COM. For example, we may use cookies to personalize your experience on STURGISTT.COM (e.g., to recognize you by name when you return to STURGISTT.COM), save your password in password-protected areas, and enable you to use shopping carts on STURGISTT.COM.

We, and our third party service providers, advertisers, advertising networks and platforms, agencies, or Partners, use cookies or other common tracking technologies to offer you products, content, offerings, or services that may be of interest to you and to deliver relevant advertising based on your interests on STURGISTT.COM, an affiliate’s website, or third-party websites or applications that you visit.

We, and our third party service providers, advertisers, advertising networks and platforms, agencies, or Partners, use cookies or other common tracking technologies to manage and measure the performance of advertisements displayed on or delivered by or through STURGISTT.COM and/or other networks or sites. This also helps us, our service providers and Partners provide more relevant advertising to you. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by this privacy statement. One such third party service we use is Google Adwords. This service allows us to serve our advertisements on websites across the Internet. You may opt out of this feature using the Ads Preferences Manager.

Synching Cookies and Identifiers. We may work with our Partners (for instance, third party ad platforms) to synchronize unique, anonymous identifiers (such as those associated with cookies) in order to match our Partner’s uniquely coded user identifiers to our own. We may do this, for instance, to enhance data points about a particular unique browser or device, and thus enable us or others to send ads that are more relevant, match users to their likely product interests, or better synchronize, cap, or optimize advertising.

Locally Stored Objects. STURGISTT.COM may employ locally stored objects (“LSOs”) and other client side storage tracking technologies in certain situations where they help to provide a better user experience, such as to remember your settings, preferences and usage, similar to browser cookies, or in order to target or help our Partners target ads, analyze ads performance, or perform user, website or market analytics. For LSOs utilized by Adobe Flash you can access your Flash management tools from Adobe’s website. In addition, some, but not all browsers, provide the ability to remove LSOs, sometimes within cookie and privacy settings.

Disabling Cookies. Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of STURGISTT.COM may be difficult to use or inoperable.

We may work with certain third-party companies that use techniques other than HTTP cookies to recognize your computer or device and/or to collect and record information about your web surfing activity, including those integrated with STURGISTT.COM. Please keep in mind that your web browser may not permit you to block the use of these techniques, and those browser settings that block conventional cookies may have no effect on such techniques. To learn more about Interest-Based Advertising and your choices for opting out of this type of advertising, please go to Opting Out: Your Ad Choices.

Web Beacons. We and our Partners may also use “web beacons” or clear GIFs, or similar technologies, which are small pieces of code placed on a web page or in an email, to monitor the behavior and collect data about the visitors viewing a web page or email from us. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).

Mobile Device Identifiers and SDKs.We also sometimes use, or partner with publishers, publisher-facing, or app developer platforms that use mobile Software Development Kits (“SDKs”), or use an SDK with a mobile app that we offer, to collect Information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), and Information connected to how mobile devices interact with STURGISTT.COM products and services and those using STURGISTT.COM. A mobile SDK is the mobile app version of a web beacon (see “Web Beacons” above). The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services or analytics to be performed. We may use this technology to deliver or help our Partners deliver certain tailored advertising through mobile applications and browsers based on information associated with your mobile device. If you’d like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions in Opting Out: Your Ad Choices.

Third parties may themselves set and access their own tracking technologies when you visit STURGISTT.COM, and they may have access to information about you and your online activities over time and across different devices, websites or applications when you use STURGISTT.COM. Their use of such tracking technologies is not in our control and is subject to their own privacy policies.

Sometimes, we may associate cookies with the Information, including de-identified, “hashed,” or anonymous versions of Information you have provided (such as during registration), in order to send or help our Partners send ads and offers based on your presumed interests or demographic information.

Opting Out: Your Ad Choices To learn about online interest-based advertising and your choices related to interest-based advertising, please visit:

For United States visitors: the Digital Advertising Alliance (“DAA”) at the Ad Choices site

For European Union visitors: the European Interactive Digital Advertising Alliance (“EDAA”) at the EDAA site

We also allow our European Union visitors to opt out of interest-based advertising on STURGISTT.COM via our consent manager.

The tools provided on the DAA opt-out page and the EDAA site are provided by third parties, not Sturgis TT. We do not control or operate these tools or the choices that advertisers and others provide through these tools.

PLEASE NOTE: Certain choices you make through these platforms may be browser-specific or device-specific. If you erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), or use a new or different computer, you may need to opt out again.

Opting out via this method does not prevent the use of cookies or similar tracking tools that are necessary for the operation of STURGISTT.COM or other legitimate purposes unrelated to serving interest-based ads. Information may still be collected about your web browsing activities for these other purposes. While you will not receive ads based on your interests derived from your online behavior, you will still see advertising, including contextual ads that are based on the content of the STURGISTT.COM pages you visit.

We sometimes utilize Adobe technology to customize advertising you may see on our site or third-party sites. These “flash cookies” cannot be controlled through browser settings, but you can opt out of the receipt of targeted advertising utilizing Adobe technology by clicking here.

When using a mobile application you may receive tailored in-application advertisements. Depending on your device, you may be able to reset your mobile device’s advertising identifier at any time by accessing the privacy settings on your mobile device. In addition, each operating system (iOS for Apple phones, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.

How We Respond to Do Not Track Signals

At this time STURGISTT.COM does not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.

What Are Your Rights and Choices?

Your right to make informed decisions about information collection is important to Sturgis TT.

Opting Out of Marketing Communications. Please note that you always have the right to opt out of having your Information shared with third parties for their own marketing purposes. To stop receiving advertising e-mails, follow the “unsubscribe” instructions in any advertising e-mail we send you (you will still receive transactional e-mails). To stop receiving text messages, reply “STOP” to any message.

If you have any questions or concerns about this Privacy Statement or if you would like to opt out from our sharing of your Information with unaffiliated third parties for the third parties’ direct marketing purposes, please contact us at communications@sturgistt.com. Please know that in order for us to respond to your request we may require that you verify your identity. Sturgis TT is based in the United States and our products are offered in English. Requests submitted in another language will require translation.

Your European Privacy Rights. Please note that if you are in the European Union or the European Economic Area, you also have the right to:

• obtain confirmation of the existence of your Information in Sturgis TT’s database
• verify the origin and accuracy of your Information
• request that we correct, update, amend, delete, or transform your Information into anonymous form
• provide you information about how we use your Information
• oppose the processing of your Information on legitimate grounds
• lodge a complaint with your local data protection authority

International Collection of Information

We collect and receive personal data from inside and outside of the United States.

If you are located in the European Union or elsewhere outside of the United States, please be aware that information we collect is processed in the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen. We put safeguards in place to protect your Information when we process it outside of the country from which it was collected.

Third Party Sites and Linked Services

STURGISTT.COM may contain links to or integrations with other sites such as Facebook, Twitter, LinkedIn, and other media services and platforms not owned or controlled by us, whose information practices may be different than ours. This privacy statement does not apply to any information collected by third-party sites or integrated services providers. You should consult the other sites’ privacy notices, as we have no control over information that is submitted to, or collected by, these third parties.

Data Security

We have put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the Information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.

The Internet is not 100% secure. Although we take reasonable measures designed to safeguard against unauthorized disclosures of Information, we cannot guarantee that your Information will never be disclosed, altered or destroyed in a manner that is inconsistent with this privacy statement.

Children’s Privacy

We do not knowingly collect Information from, and do not create user segments targeted to, children under 13 years of age. If you believe your child or someone else has provided Sturgis TT with Information about your child and you would like to have the Information removed, please contact us, and we will use reasonable efforts to promptly remove such information from our records.

How to Contact Us

If you have any questions or concerns about Sturgis TT’s privacy statement, you may contact us at this email address: communications@sturgistt.com, or you can send correspondence to the following address:

Sturgis TT

Legal Department

525 Fentress Blvd., Suite B

Daytona Beach, FL 32114

Updates

From time to time, we may update this privacy statement. We will notify you about material changes by prominently posting a notice on our site or otherwise as required by law. We encourage you to periodically check back and review this statement so that you always will know what information we collect, how we use it, and with whom we share it.

Rights for Our California Residents

This section explains how we collect and share personal information about California residents (“California Customers”) and their privacy rights.

I. Notice of Information Collection for California Consumers 

II. Your California Privacy Rights

What Rights Do You Have?

• Right to Know – You have the right to ask us to tell you what personal information of yours we collect, use, share or sell.
• Right to Access – You have the right to request access to the personal information of yours we collect or maintain.
• Right to Request Deletion – You have the right to ask us to delete the personal information we collect or maintain about you.
• No Discrimination – You have the right not to be discriminated against for exercising the rights above.

You also have Shine the Light Rights – You have the right to request and obtain from us, once a year and free of charge, a list of the third parties to whom we have disclosed certain types of personal information (if any) for their direct marketing purposes in the prior calendar year. At our option, we may respond to such requests by providing instructions about how our users can exercise their options to prevent our disclosure of personal information to third parties for their direct marketing purposes.

III. How Do You Submit These Requests to Us?

California residents can exercise these rights:

• Shine the Light Rights
• Requests to Access/Know
• Request to Delete

By contacting us by:

• Email: communications@sturgistt.com

We will need to verify that you are who you say you are before we delete or share personal information with you. If you make a request via email, we may need to request more information from you in order to verify your request.

Privacy Statement, April 7, 2023

© 2023 Sturgis TT