Privacy Policy

Effective date: January 1, 2026

1. Introduction

This Privacy Policy (“Policy”) describes how The Jay Group Inc. (“Jay Group,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes personal information in connection with our website and any related online services that link to this Policy (collectively, the “Site”). This Policy does not apply to information processed in connection with logistics, warehousing, fulfillment, or other commercial services provided by Jay Group to its customers, which is governed by the applicable written services agreement between Jay Group and the customer.

By accessing or using the Site, you acknowledge that you have read, understood, and agree to be bound by this Policy and our Terms of Use. If you do not agree to this Policy, do not access or use the Site.

2. Scope

This Policy applies only to personal information collected through the Site. It does not apply to:

• Information collected offline or through channels other than the Site
• Information collected by third parties, including through third-party websites, applications, or services linked to or from the Site
• Information processed in connection with Jay Group’s commercial services to its customers, which is governed by separate written agreements
• Information about Jay Group’s employees, contractors, or job applicants, which is governed by separate notices

3. Information We Collect

We may collect the following categories of information:

Information you provide directly. When you contact us, request a quote, subscribe to communications, submit User Content, or otherwise interact with the Site, you may provide information such as your name, email address, phone number, company name, job title, mailing address, and the content of your communications.

Information collected automatically. When you access the Site, we and our service providers may automatically collect certain information, including:

• Device and browser information (such as device type, operating system, browser type and version, and unique device identifiers)
• Network and connection information (such as Internet Protocol (IP) address and Internet service provider)
• Usage information (such as pages visited, links clicked, time and date of access, referring URL, and other actions taken on the Site)
• Location information (such as general geographic location inferred from IP address; we do not collect precise geolocation)

Information from cookies and similar technologies. We and our service providers use cookies, pixels, web beacons, local storage, and similar technologies to collect information about your use of the Site. For more information, see Section 7 (Cookies and Tracking Technologies).

Information from third parties. We may receive information about you from third parties, including analytics providers, advertising networks, data brokers, and publicly available sources.

Information we do not collect. We do not knowingly collect sensitive personal information as defined by the California Consumer Privacy Act, including Social Security numbers, driver’s license numbers, financial account credentials, precise geolocation, racial or ethnic origin, religious beliefs, union membership, genetic data, biometric data, health information, or sexual orientation.

4. How We Use Information

We may use the information we collect for the following purposes:

• To operate, maintain, and improve the Site
• To respond to your inquiries and fulfill your requests
• To send you administrative communications, such as updates to our Terms of Use or this Policy
• To send you marketing and promotional communications, where permitted by law and subject to your preferences
• To personalize your experience on the Site
• To analyze usage trends and improve our services
• To detect, investigate, and prevent fraud, security incidents, and other harmful or unauthorized activities
• To comply with legal obligations and enforce our Terms of Use
• To protect the rights, property, or safety of Jay Group, our users, or others
• For any other purpose disclosed to you at the time of collection or with your consent

5. How We Share Information

We may share the information we collect in the following circumstances:

Service providers. We share information with third-party service providers that perform services on our behalf, such as website hosting, analytics, email delivery, customer relationship management, accessibility tools, and marketing. These service providers are contractually obligated to use the information only for the purposes for which it was disclosed and in accordance with this Policy.

Business transfers. We may share or transfer information in connection with, or during negotiations of, any merger, acquisition, sale of assets, financing, bankruptcy, reorganization, or other business transaction involving all or a portion of Jay Group.

Legal compliance and protection. We may disclose information if we believe in good faith that disclosure is necessary to: (a) comply with applicable law, regulation, legal process, or governmental request; (b) enforce our Terms of Use or other agreements; (c) protect the rights, property, or safety of Jay Group, our users, or others; or (d) detect, investigate, or prevent fraud or other harmful activities.

Affiliates. We may share information with our affiliates for purposes consistent with this Policy.

With your consent. We may share information for any other purpose disclosed to you at the time of collection or with your consent.

Aggregate or de-identified information. We may share aggregate, anonymized, or de-identified information that cannot reasonably be used to identify you.

We do not sell personal information for monetary consideration. We do not share personal information for cross-context behavioral advertising.

6. Third-Party Websites and Services

The Site may contain links to, or integrations with, third-party websites, applications, or services that are not owned or controlled by Jay Group. This Policy does not apply to any third-party websites, applications, or services. We are not responsible for the privacy practices of any third party and encourage you to review the privacy policies of any third-party websites, applications, or services you visit or use.

7. Cookies and Tracking Technologies

We and our service providers use cookies and similar technologies to collect information, enhance your experience, and analyze usage of the Site.

Cookies. A cookie is a small text file stored on your device when you visit a website. We use both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device until deleted or expired).

Types of cookies we use:

• Essential cookies: Necessary for the Site to function and cannot be disabled.
• Analytics cookies: Help us understand how visitors interact with the Site.
• Functional cookies: Enable enhanced functionality and personalization.
• Marketing cookies: Used to deliver relevant advertisements and track campaign effectiveness.
• Accessibility cookies: Used by our accessibility solution to remember your accessibility preferences.

Accessibility tool. We deploy UserWay’s accessibility widget to help visitors adjust visual presentation, navigation, and content delivery according to individual preferences. UserWay may use cookies or local storage to remember your accessibility settings across sessions. UserWay’s collection and use of information is governed by UserWay’s privacy policy, available at https://userway.org/privacy. Jay Group does not control and is not responsible for UserWay’s data practices. The deployment of UserWay does not by itself constitute, guarantee, or substitute for compliance with any specific accessibility law, regulation, standard, or guideline.

Your choices. Most browsers allow you to manage cookie preferences through browser settings. You may also opt out of certain analytics and advertising cookies through industry opt-out tools. Please note that disabling cookies may affect the functionality of the Site, including accessibility features that rely on stored preferences.

Do Not Track. Some browsers transmit “Do Not Track” signals. The Site does not currently respond to Do Not Track signals. However, you may manage your cookie preferences as described above.

8. Data Security and Breach Notification

Jay Group implements administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and destruction. However, no method of transmission over the Internet or method of electronic storage is completely secure. Jay Group cannot guarantee the absolute security of your information, and any transmission of personal information is at your own risk.

In the event of a security incident involving personal information, Jay Group will notify affected individuals and regulatory authorities as required by applicable law, including the Pennsylvania Breach of Personal Information Notification Act (73 P.S. § 2301 et seq.). Jay Group reserves the right to determine the timing, content, and method of any notification in its sole discretion, consistent with applicable legal requirements and law enforcement guidance.

9. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. As a general guideline, we typically retain personal information for up to three (3) years after your last interaction with the Site, unless a longer retention period is required by law, necessary for legal claims, or subject to a litigation hold. The retention period may vary depending on the context, the nature of the information, and applicable legal requirements.

10. Children’s Privacy

The Site is not directed to children under the age of eighteen (18), and we do not knowingly collect personal information from children under eighteen (18). If we learn that we have collected personal information from a child under eighteen (18), we will take steps to delete such information as soon as practicable. If you believe that a child under eighteen (18) has provided personal information to us, please contact us using the information in Section 21.

11. Your Rights and Choices

Marketing communications. You may opt out of receiving marketing emails from us by following the unsubscribe instructions in those emails. Even if you opt out of marketing emails, we may still send you administrative communications.

Access and correction. You may request access to or correction of your personal information by contacting us using the information in Section 21. We will respond to your request in accordance with applicable law.

Additional rights. Depending on your jurisdiction, you may have additional rights with respect to your personal information, as described in Sections 12 and 13.

12. California Residents

This section applies to California residents and supplements the information in this Policy.

Categories of personal information collected. In the preceding twelve (12) months, we may have collected the following categories of personal information, as defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”): identifiers; commercial information; Internet or other electronic network activity information; geolocation data (general, not precise); and inferences drawn from the above.

Sensitive personal information. We do not knowingly collect sensitive personal information as defined by the CCPA, including Social Security numbers, driver’s license numbers, financial account credentials, precise geolocation, racial or ethnic origin, religious beliefs, union membership, genetic data, biometric data, health information, or sexual orientation. Because we do not collect sensitive personal information, we do not offer a “right to limit” the use of such information.

Sources. We collect personal information from the sources described in Section 3.

Purposes. We collect and use personal information for the business and commercial purposes described in Section 4.

Disclosure. We may disclose personal information to the categories of recipients described in Section 5.

Sale and sharing. We do not sell personal information for monetary consideration. We do not share personal information for cross-context behavioral advertising.

Retention. We retain personal information as described in Section 9.

Your California privacy rights. Subject to certain exceptions, California residents have the following rights under the CCPA:

• Right to know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes for collection, the categories of third parties with whom we share personal information, and the categories of personal information disclosed.
• Right to delete: You have the right to request that we delete personal information we have collected from you, subject to certain exceptions.
• Right to correct: You have the right to request that we correct inaccurate personal information we maintain about you.
• Right to opt out of sale or sharing: You have the right to opt out of the sale or sharing of your personal information. As noted above, we do not sell or share personal information.
• Right to non-discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA rights.

Submitting requests. To submit a request to know, delete, or correct, please contact us using the information in Section 21. We will verify your identity before processing your request. You may designate an authorized agent to submit a request on your behalf by providing signed written authorization or a valid power of attorney.

Response timing. We will respond to verifiable consumer requests within forty-five (45) days, or notify you if we require additional time (up to an additional forty-five (45) days).

13. Other State Privacy Laws

Residents of certain other states, including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, and other states with comprehensive consumer privacy laws, may have additional rights with respect to their personal information, including the right to access, correct, delete, or obtain a copy of personal information, and the right to opt out of certain processing activities. To exercise any applicable rights, please contact us using the information in Section 21. We will respond to verifiable requests within the timeframes required by applicable law, generally forty-five (45) days.

14. International Visitors

Jay Group is headquartered in the United States, and the Site is intended for users located in the United States. We do not target, market to, or knowingly collect personal information from individuals located in the European Economic Area, United Kingdom, Switzerland, or other jurisdictions outside the United States.

If you access the Site from outside the United States, you do so at your own initiative and are solely responsible for compliance with local laws. By using the Site, you consent to the transfer of your information to the United States, where data protection laws may differ from those in your jurisdiction.

Jay Group does not represent or warrant compliance with the European Union General Data Protection Regulation (GDPR), the UK GDPR, the Swiss Federal Act on Data Protection, the European Accessibility Act, or any other non-U.S. data protection framework. Jay Group is not subject to the jurisdiction of any non-U.S. data protection authority with respect to the Site.

15. Changes to This Policy

Jay Group may update this Policy from time to time by posting the revised Policy on the Site and updating the “Effective date” above. Material changes will be effective upon posting unless otherwise noted. Your continued use of the Site after the effective date of any modification constitutes your acceptance of the modified Policy. If you do not agree to the modified Policy, you must stop using the Site.

16. Construction; No Warranty; No Admission

This Policy reflects Jay Group’s good-faith intentions and practices regarding personal information. This Policy is not a contract, a warranty, or a representation of compliance with any specific law, regulation, standard, or guideline at any particular time. Nothing in this Policy should be construed as an admission of liability or non-compliance under any applicable privacy law, including without limitation the California Consumer Privacy Act, the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Texas Data Privacy and Security Act, the European Union General Data Protection Regulation, or any other legal authority.

Jay Group does not represent or warrant that its data practices are free from risk or error at any given time, nor that they conform to any particular privacy standard at any given time. Statements regarding intended practices, controls, or future actions are aspirational and forward-looking and are not commitments enforceable as contractual obligations except to the extent expressly set forth herein.

The deployment of any third-party tool, service, or integration, including UserWay, analytics providers, or marketing platforms, does not by itself constitute, guarantee, or substitute for compliance with any specific privacy law, regulation, standard, or guideline. Any reference in this Policy to a tool, standard, framework, or process is descriptive only and is not a representation of conformance with that standard or framework.

17. Limitation of Liability

To the fullest extent permitted by law, Jay Group, its affiliates, and its and their respective directors, officers, employees, agents, contractors, and licensors will not be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages arising out of or in connection with the collection, use, disclosure, or security of personal information, whether based on warranty, contract, tort (including negligence), statute, or any other legal theory, even if Jay Group has been advised of the possibility of such damages.

To the fullest extent permitted by law, the aggregate liability of Jay Group arising out of or in connection with this Policy or the processing of personal information will not exceed one hundred United States dollars (US$100).

The limitations in this section do not apply to liability arising from Jay Group’s gross negligence, willful misconduct, or fraud, or to any liability that cannot be limited or excluded under applicable law, including statutory damages under privacy laws that expressly prohibit limitation.

18. Dispute Resolution; Incorporation of Terms of Use

All disputes arising out of or relating to this Policy, including disputes regarding the collection, use, disclosure, or security of personal information, are subject to the dispute resolution provisions of our Terms of Use, including the binding arbitration agreement, class action waiver, jury trial waiver, informal resolution requirement, and time limit for claims set forth therein. By using the Site, you agree that any privacy-related dispute will be resolved through individual arbitration rather than in court, to the fullest extent permitted by law.

Your indemnification obligations under our Terms of Use apply to any claim arising out of or related to personal information you provide, including any claim that information you submitted was false, misleading, inaccurate, or violated the rights of any third party.

To the extent not expressly addressed in this Policy, the Terms of Use govern your use of the Site and are incorporated herein by reference.

19. Governing Law

This Policy and any dispute arising out of or related to it will be governed by and construed in accordance with the laws of the Commonwealth of Pennsylvania, without giving effect to its conflict of laws principles, consistent with the Terms of Use.

20. Force Majeure

Jay Group will not be liable for any failure or delay in performance of its obligations under this Policy arising out of or resulting from causes beyond its reasonable control, including acts of God, natural disasters, pandemics, war, terrorism, civil unrest, labor disputes, governmental action, cyber-attacks, failures or interruptions of utilities or telecommunications, or any other force majeure event.

21. Contact

If you have questions about this Policy or wish to exercise your privacy rights, please contact us:

The Jay Group Inc.
700 Indian Springs Dr.
Lancaster, PA 17601, United States

Attention: Natalia Golenkova
Email: Natalia.Golenkova@jaygroup.com or google.marketing@jaygroup.com
Phone: 717-285-6200

© 2026 The Jay Group Inc. All rights reserved.