Privacy Policy

Latest update: September 2024 

This Privacy Policy informs you of how your Personal Information is used in connection with 2112 Industries websites and its brands. 2112 Industries’ entities, websites, brands include: Spry Manufacturing, LLC, Craftmade Foods, LLC, 2112industries.com, sprymfg.com, swivels.com, craftmadefoods.com (hereinafter “2112 Industries” or “we”, “us”, our “Sites” or “Site” etc.). 

The term “Personal Information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. Personal Information does not include information that is publicly available, de-identified, or aggregated.  

“Personal Information” also includes social security number, driver license number, state identification card, passport number, financial data, genetic data, biometric data, precise geolocation, and racial and ethnic origin, content of consumer communications (email, mail, or text), unless the business is the intended recipient, genetic data, and information collected concerning a consumer’s health, sex life, or sexual orientation. 

Please review this Privacy Policy carefully to understand how we collect, use, protect, or otherwise handle your Personal Information in accordance with using our Sites. California residents should review Section 9 for applicable California rights.  

Spry Manufacturing, LLC, Swivels Custom Material Handling Carts, Craftmade Foods, LLC may process your Personal Information as data controllers. You may contact any of these entities by using the contact information set out in Section 10. 

1. Collecting Personal Information 

We collect Personal Information from you in a variety of circumstances, including when you visit our Sites. We have set out below the Personal Information we collect and the circumstances in which we collect such Personal Information. Please note that the type of Personal Information collected may vary depending on the nature of your interactions with us. 

Category of Personal Information and Specific Pieces Collected 

Categories of Sources from which Personal Information Collected 

Personal Identifiers 
 
Personal Information that includes real name, alias, postal address, unique personal identifier, online identifier, IP address, cookies that identify, email address, account name, search terms, what kinds of products you view, type of browser, time zone. 
 
Your job application information: Resume/CV, cover letter, EEOC compliance information such as gender and ethnicity, disability and veteran status, and interview notes, or other similar identifiers. 

Directly from you when you create an account, when you communicate with us, when you make a purchase, when we fulfill a purchase, when you give consent to receive our newsletters and other commercial information from us, and other activities where you submit Personal Information to us 

Cookies we collect from you through browsing the Sites 

Commercial Information 
 
Your account log in, financial account, payment information, billing address, debit card, or credit card number in combination with any required security or access code, password or credentials allowing access to an account used to submit orders and make purchases on the Sites, 
Your transactions and payment information: details of the product and services transaction, payment methods, shipping methods, terms and other fulfilment and customer relation information; 

Directly from you 

Internet or other electronic network activity information 
 
This includes browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement 

 

Directly from you 

Cookies we collect from you through browsing the Sites 

 

Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

 

Directly from you 

Cookies we collect from you through browsing the Site 

 

 

2. Purpose for Collection 

We use the Personal Information we collect from you for a variety of business reasons as indicated below.   

Purposes for Collection / Use 

Legal basis for Collection/Use 

Commercial purposes 

To handle any questions, quotes or requests you may have 

To perform a transaction 

To process your transactions, orders, and your payments 

To fulfill your orders and provide refunds 

To deliver products or services to you 

To generally manage your transactions and payments 

To provide customer support 

To inform you about products, services, and commercial information about us 

To allow us to better service you in responding to your customer service requests 

To provide authentications necessary to perform transactions and other services 

To enable you to register or maintain an account with us 

To screen orders for potential risk or fraud 

The performance of contract, including to fulfill your orders, deliver products or services to you and the management of your transactions and payments. 
 
Our legitimate interest, more specifically our interest in having clear communications with you and in understanding your needs and expectations. 

General management 

To manage our business, affairs and staff 

To buy or sell any business, assets or shares or for business restructurings 

 

Marketing 

To provide you with appropriate products, recommendations, and updates 

To register or maintain an account or subscribe to marketing emails from us 

For marketing purposes to personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested 

To show you relevant ads while you are browsing the internet or using social media 

 
 
Our legitimate interest, more specifically our interest to inform you of offers, products, industry information, services and general information about us and our products and services. 

Recruitment 
 
To handle your job application submitted online on one of our Sites. 

Our legitimate interest, more specifically our interest in responding to your job applications and finding suitable profiles for the positions available within 2112 Industries. 

Site management 
 
To improve and test our Sites to better serve you 
To improve the Sites, set default options, and provide you with a better shopping experience 

Our legitimate interest and more specifically our financial interest in continually improving our websites and our services and in understanding your needs to be able to meet your expectations. 

 

3. Sharing of Personal Information 

2112 Industries may share your Personal Information with others including: 

  • 2112 Industries, its affiliates and group entities and brands 
  • Service providers who provide order fulfillment services  
  • Payment processors  
  • Service providers who provide website hosting and data processing services for our Sites 
  • Service providers who provide marketing services to us  
  • Social media platforms used for advertising 
  • Service providers who assist us with calculation and management of state sales taxes (e.g. Avalara) 
  • Service providers who provide employee relates services and benefits 
  • Advisers, including professional advisers 
  • Potential buyers of business, assets or shares from us or our owners  

We may also disclose your Personal Information to third parties if disclosure is required to comply with applicable laws or regulations; comply with legal process or a court order; to respond to requests from public and government authorities; or if disclosure is necessary to enforce our Privacy Policy and/or Terms of Use; to protect your safety or security; to protect our rights, the safety and security of our Sites and property or that of 2112 Industries or third parties; to allow us to pursue available remedies or limit the damages we may sustain. 

We may share or transfer your Personal Information to a third party if 2112 Industries enters, or is involved in, a business transaction such as a merger, acquisition, reorganization, or sale of some or all of its assets. 

When sharing Personal Information with third parties, we will ensure that we comply with applicable legal requirements, including where Personal Information is being transferred from United Kingdom or Europe to the extent applicable, we ensure appropriate safeguards are put in place.  

4. Retention Period 

2112 Industries will keep your Personal Information for a minimum of 12 months and as long as necessary to achieve the purposes for which they are collected and processed. 2112 Industries may, however, keep your Personal Information for a longer period for accounting and customer relations, or whenever there is a legal obligation for us or to consider the applicable statute of limitation period to assert, exercise or defend legal claims. 

Our retention period varies depending on the nature of the Personal Information collected by 2112 Industries. The following retention periods apply: 

  • When you agree to receive marketing communications, 2112 Industries will keep your Personal Information until you indicate that you no longer wish to receive such communications, or otherwise for the period defined by applicable legislation. 
  • When your Personal Information is collected in the context of requests/queries relating to IT services and applications, 2112 Industries will keep your data for the period necessary to process such requests or queries. 
  • Job application files can be kept up to 3 years from the date of last contact with the applicant, unless the applicant agrees to a longer period; in such case, the Personal Information can be archived in accordance with the applicable statute of limitation periods. 
5. Cookies 

You are informed that, when browsing our websites, cookies can be placed on your web browser to enable you to benefit from optimal browsing. Cookies are data stored on the equipment of an Internet user. Our websites use cookies to send information to the user’s browser, enabling the browser to pass data back to the original website (for instance, a session ID, if you’re returning to Site or a date). Other types of trackers, such as Web beacons, can also be used. These beacons make calls to servers to display a pixel and enable us to share data with third parties for the purposes described in our Cookie Management Policy. 

6. Minors 

Our Sites are not intended for individuals under the age of 16. We do not intentionally collect Personal Information from children. If you are a parent or guardian who believes your child has provided us with Personal Information, please contact us using the contact information provided at the end of this policy. 

7. Security 

2112 Industries will ensure the security of your Personal Information through a data protection system that uses physical and logical security measures. 

8. Email Communications 

The CAN-SPAM Act gives recipients of commercial email the right to have emails stopped from being sent to them. You may unsubscribe from our marketing communications by clicking the “unsubscribe” link found in every commercial email we send, or (if you have an account with us) by sending us a request to unsubscribe. If you opt-out of receiving our marketing email communications, we may still send you email messages related to your account or specific transactions with us. Unsubscribing yourself from our marketing emails will not affect our service to you. 

Emails that we and our marketing service providers send may include tracking tools that provide us with information related to whether you’ve opened an email or clicked on a link contained in an email.  

9. Your California Rights 

The following rights are available to California residents pursuant to the California Consumer Privacy Rights Act of 2018 (“CCPA”). 

Right to Opt-Out of the Sale and Sharing of Your Personal Information.  

California residents may opt-out of the sale of their Personal Information or the sharing of their Personal Information for cross-context behavioral advertising. 2112 Industries does not sell your Personal Information.   

Right to Limit the Use of Your Sensitive Personal Information. 

Effective January 1, 2023 pursuant to the California Privacy Rights Act (“CPRA”), if you are a California consumer, you may direct us to limit the use of your sensitive Personal Information to uses that are reasonably necessary to provide our goods and services, or as needed: to ensure security and integrity; for short-term, transient use, including for non-personalized advertising; to maintain or service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide financing, provide analytic services, provide storage, or other similar services; and to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices.   

We do not use your sensitive Personal Information beyond the purposes necessary to perform functions of our business. As such, this right is not applicable.  

Right to Request More Information.  

This Privacy Policy discloses our practices with respect to the collection of your Personal Information. In addition to these disclosures, you may also submit a request to know the following information collected during the preceding 12 months: (1) the specific pieces of Personal Information we have collected about you; (2) the categories of Personal Information we collected about you; (3) the categories of Personal Information we sold or shared about you and the categories of third parties to whom each category of Personal Information was sold or shared; (4) the categories of Personal Information we disclosed about you for a business purpose and the categories of persons to whom it was disclosed; and (5) a list of all third parties to whom we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes. 

Please note that due to the different requirements of the applicable laws, our response times may vary depending on the specific type(s) of information sought. We respond to all verifiable requests for information as soon as we reasonably can and no later than legally required. 

Right to Request Deletion of Your Personal Information.  

You have the right to request that we delete your Personal Information. Following receipt of a verifiable request, we will let you know what, if any, Personal Information we can delete from our records. Effective January 1, 2023, pursuant to the CPRA, we will also notify our service providers and contractors, and any third parties to whom we have transferred your information about your request to delete. If we cannot delete all your Personal Information, we will let you know why.  

Right to Correct Inaccurate Information.  

Effective January 1, 2023, pursuant to the CPRA, if you believe that any of the Personal Information, we maintain about you is inaccurate, you may submit a request for us to correct that information. Upon receipt of a verifiable request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct the information as you direct.  

Right to Non-Discrimination for the Exercise of Your Privacy Rights 

If you choose to exercise any of your California rights, you have the right to not receive discriminatory treatment by us. 

Submitting Requests Relating to Your California Rights 

California residents may submit requests relating to your Personal Information as described below by email to Privacy@2112industries.com, or by calling us at 1-866-761-7225. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with any of the requests described below. To verify your identity, we may require you to provide certain information we are likely to already have on-file about you based on the type of relationship you have with us. If you already have an account, we may require you to use that account as part of the verification process. If you exercise your right to request specific pieces of your Personal Information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. If you would like to designate an authorized agent to submit these requests on your behalf, please contact us by email to Privacy@2112industries.com, or by calling us at 1-866-761-7225. 

 

11. Links to Third-Party Websites 

While browsing our Sites, you may come across content containing links to third-party applications and websites. 2112 Industries has no control over the cookies or other functions used by such third-party applications and websites, and any Personal Information processing that may be implemented by such applications and websites are not governed by this Privacy Policy. 

Accordingly, it is up to you to directly contact and/or visit such third-party applications and websites to obtain further information on their data protection guidelines. 

12. Contact Us 

If you would like more information about this Privacy Policy or how we process your Personal Information, please contact:  

Email: Privacy@2112industries.com  

Address: 71 Innovation Way, Andrews, South Carolina, 29510 USA 

13. Changes to Policy 

2112 Industries may update this Privacy Policy at any time to reflect possible new practices and service offers. In such case, the date of this Privacy Policy will be updated and indicate the date when such changes were made. We invite you to check for any possible updates of this Privacy Policy, which will be published on the Sites.  

This Privacy Policy may be updated at any time, so we advise you to check for updates from time to time.