JS Wright LLC (“Company” or “we” or “us” or “our” or “JS Wright”) respects the privacy of its users (“user” or “you”) that use our website located at jswrightllc.com, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Website”). The following JS Wright privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that JS Wright may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which JS Wright uses and discloses that information, as well as your rights in relation to that information. We do not share customer data, including Personally-Identifying Information, with third parties for their marketing purposes without your explicit consent. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website, you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Website.

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the website and your agreements with us. Any persons accessing our website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use, and disclosure. Different from those of the jurisdictions mentioned above, they may only use the Website in a manner lawful in their jurisdiction. If your use of the Website is unlawful in your jurisdiction, please do not use the Website.

BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.
GATHERING, USE, AND DISCLOSURE OF THIS NON-PERSONALLY-IDENTIFYING INFORMATION

The user of the Website Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, JS Wright gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites that users views right before arriving at, while navigation and immediately after leaving the website. Although such information is not Personally-Identifying Information, it may be possible for JS Wright to determine from an IP address a user’s internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. JS Wright analyzes Non-Personally-Identifying Information gathered from users of the website to help JS Wright better understand how the website is being used. By identifying patterns and trends in usage, JS Wright is able to better design the website to improve users’ experiences, both in terms of content and easy of use. From time to time, JS Wright may also release Non-Personally-Identifying Information gathered from website users in the aggregate, such as by publishing a report on trends in the usage of the website.

Analytics
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past activity on the Website including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyzing and track data, determine the popularity of certain content and better understand online activity. If you do not want any information collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt from Google Analytics for Displaying Advertising or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads).

Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third-parties and our affiliate companies to develop and deliver targeted advertising on the website and on websites of third-parties. We may combine Non-Personally-Identifying Information we collect with additional Non-Personally-Identifying Information collected from other sources. We also may share aggregated information with third-parties, including advisors, advertisers and investors, for the purposes of conducting general business analysis.

Social Media
We may use hyperlinks on the website, which will redirect you to a social network if you click on the respective link or icon. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “Tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. For example, when you click on Facebook’s “Like” button on the website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the website. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.

COLLECTION, USE, AND DISCLOSURE OF PERSONALLY-IDENTIFYING-INFORMATION
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. JS Wright may collect a range of Personally-Identifying Information from and about website users. Much of the Personally-Identifying Information collected by JS Wright about users is information provided by users themselves when (1) registering for our service, (2) logging in with social network credentials, (3) participating in polls, contests, surveys, or other features of our service, or responding to offers or advertisements, (4) communicating with us, (5) or signing up to receive newsletters. That information may include each user’s name, address, email address, and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date, or other financial information.) We also may request information about your interest and activities, your gender, age, date of birth, username, hometown, and other demographic or relevant information as determined by JS Wright from time to time. Users of the website are under no obligation to provide JS Wright with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain website features. We do not share mobile opt-in information with any third parties for any purpose.

BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.

Company Communications
We may occasionally use your name and email address to send you notifications regarding new services offered by JS Wright that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.

Company Disclosures
JS Wright will disclose Personally-Identifying Information under the following circumstances:

General Use
JS Wright uses the Personally-Identifying Information in the file we maintain about you and other information we obtain from your current and past activities on the website (1) to deliver the products and services that you have requested; (2) to manage your account and provide you with customer support; (3) to communicate with you by mail, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us or affiliate companies or other third parties; (4) to develop and display content and advertising tailored to your interests on the website and other sites; (5) to resolve disputes and troubleshoot problems; (6) to measure consumer interests in our services; (7) to inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud, and other criminal activity: (10) to enforce our Terms of Use, and (11) to do as otherwise described to you at the time of collection. At times we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifying Information to identify users using multiple IDs or aliases. We may compare and review your Personally-Identifying Information for accuracy and detect errors or omissions.

COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
JS Wright contractually prohibits its contractors, affiliates, vendors, and suppliers from disclosing Personally-Identifying Information received from JS Wright other than in accordance with this Privacy Policy. However, third-parties are under no obligation to comply with this Privacy Policy with respect to the Personally-Identifying Information that users provide directly to those third parties, or that those third parties collect for themselves. These third parties include advertisers, providers of games, utilities, widgets and a variety of other third-party applications accessible through the website. JS Wright neither owns nor controls the third-party websites and applications accessible through StandardPHA.com. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third party or using a third-party application, whether by means of a link on the website, directly through the website, or otherwise, and before providing any Personally-Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application and should take those steps if necessary to, in those users’ discretion, protect their privacy.

SECURITY
We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.

We are dedicated to protect all information on the website as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information.

PRIVACY POLICY CHANGES
JS Wright may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to JS Wright’s Privacy Policy will be reflected on this page, and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you. Users should regularly check this page for any changes to this Privacy Policy. JS Wright will always post new versions of the Privacy Policy on the StandardPHA.com website. However, JS Wright may as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email and otherwise. Accordingly, it is important that users always maintain and update their contact information.

CHILDREN
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally-Identifying Information through the website represents to us that he or she is 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 that has transferred Personally-Identifying Information to the website, please contact JS Wright using our “Contact Us” page to have that child’s information deleted.

CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below:

DO-NOT-TRACK-POLICY
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the StandardPHA.com website does not respond to DNT browser signals or mechanisms.

CONTACT
If you have any questions regarding our Privacy Policy, please contact our Web Department at:

JS Wright, LLC
Attn: Web Department
8 Beaver St.
Carbondale PA, 18407