PRIVACY POLICY

Last Updated May 2025

In this Privacy Policy (the “Policy), “HBH”, “we”, “us”, or “our” refers to HBH Holdings, Inc. HBH is committed to protecting your personal information. This Policy informs you about our practices regarding the treatment of information we collect from you online, the kinds of information we collect, how that information is used, with whom we share it, and how you can opt-out of a use, or correct or change such information. Your use of our site https://hbhholdingsinc.com/ (the “Site”) is subject to the terms of this Policy.

PLEASE READ THE ENTIRE POLICY CAREFULLY BEFORE YOU CONTINUE. BY ACCESSING THIS WEBSITE OR USING ANY OF ITS FEATURES, YOU AGREE TO THE TERMS OF THIS POLICY AND ARE DEEMED TO HAVE ACCEPTED THE TERMS OF THIS POLICY IN THEIR ENTIRETY. IF YOU DO NOT AGREE, PLEASE REDIRECT YOUR BROWSER AND EXIT THE WEBSITE.

Collection and Use of Information

The information we collect depends on what you do when you visit the Site.  Please note that we do not collect personally-identifying information about you, including your name, email address, telephone number or postal address (your “PII” or “personal information”), when you visit our website, unless you choose to voluntarily provide such information to us, such as by contacting us through the use of the Contact Us form on the Site. If at any time you do provide us with such information, we will collect it and use it for the purpose for which you provided it (e.g., to respond to inquiries received from the use of any contact forms on the Site and to assess and handle any inquiries and requests, provide customer support, and to develop and improve our services). We may process your data when it is reasonably necessary to achieve our legitimate business interests. Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

You always have the option not to provide the information we request. If you choose not to provide the information we request, you can still visit the Site, but you may be required to provide your information by other means if we need such information to provide our services to you.

Most web browsers and some mobile operating systems and mobile applications 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. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a uniform standard for online tracking is adopted that we must follow in the future, we will comply with such standard, and will inform you about that practice in a revised version of this Privacy Policy.

Use of Personally-Identifying Information by Third Parties

As a general rule, we will not disclose any of your personal information except to our affiliated companies. We may disclose your personal information when (i) we have your permission; (ii) under special circumstances, such as when we believe in good faith that the law requires it; or (iii) under the circumstances described below.

We do not rent or sell email addresses, postal addresses or telephone contact information to third parties, or otherwise share any PII we collect, with any third parties (other than our affiliated entities) except as set forth below:

We reserve the right to transfer PII to a third party in conjunction with the sale or similar transfer of HBH and/or its assets.

We reserve the right to transfer PII to a third party as required by law or when we believe that disclosure is necessary to protect our rights, to comply with a court order or other legal process, to cooperate with authorities in connection with investigations of crimes or other wrongdoing, and to protect your vital interests or those vital interests of another natural person.

Use of Cookies

Cookies are pieces of information which a website transfers to your computer’s hard disk for record-keeping purposes. Cookies can make a website more useful by personalizing information for visitors and by storing information about your preferences on our site. A cookie is a small data file that is written to a computer’s hard drive by a web browser. A cookie file can contain and/or automatically collect information, such as a user identification code or IP address that a website will use to track the pages and number of times you have visited. The use of cookies is an industry standard, and many major websites use them to provide useful features for their customers. It is our policy to use cookies only for the following purposes:

To identify you;

To customize our site for you; and

To help improve navigation

Most browsers are initially set up to accept cookies. If you prefer, you can set your browser to reject cookies. However, you will not be able to take full advantage of our website if you do so.

We use tracking technology to better understand site traffic patterns and use. However, none of the information collected via tracking technology is PII.

Web Beacons

Our web pages may contain electronic images known as web beacons (invisible images often referred to as pixel tags or clear GIFs) on the Site in order to recognize users, assess traffic patterns, identify preferred content, and measure Site engagement. We may also include web beacons in our e-mail messages in order to count how many e-mail messages have been opened, for example.

Some of these web beacons may also be placed by third-party service providers to help determine the effectiveness of advertising campaigns. These web beacons may be used by third-party service providers to place a persistent cookie on your computer. This allows the service provider to recognize your computer each time you visit certain web pages and compiles anonymous information in relation to those page views, which in turn enables us and our third-party service providers to learn which advertisements bring you to our website and how you use the Site.

Analytics

We use third-party web beacons (Google Analytics®) from Google to help analyze where visitors go and what they do while visiting the Site. Analytic Services do not collect PII, identify individual users, or associate your IP address with any other data. We do not share any PII with our Analytic Services in connection with their performing of any services on the Site. We use reports provided by Analytic Services to help us understand website traffic and webpage usage.

We collect non-PII, such as IP addresses, operating systems, links clicked, pages visited, browser type, time zone setting, browser plug-in types, and referring websites of visitors to the Site. This information is collected for statistical analysis purposes, such as to determine web-traffic trends and the effectiveness of our partnerships with other websites, and to maintain the security and operation of the Site. Google’s ability to use and share information about your visit to the Site is subject to Google’s Privacy Policy (accessible here: https://policies.google.com/privacy).

Log Files

Our servers log information about your IP address, your browser type, and the current URL you are requesting. This information is always provided by your browser and automatically logged. These log files are stored in a secure location and used in our internal analysis of traffic patterns.

Security

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it, and to guard that information against loss, misuse or alteration.  When you enter sensitive information and/or PII on our Contact Us form, we encrypt that information using secure socket layer technology (SSL).

Please note, however, that no method of transmission over the internet, or method of electronic storage, is 100% secure.  Therefore, while we use commercially-reasonable means to protect your personal information, we cannot guarantee its absolute security.

Retention

We will only keep your personal information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this Policy will require us to keep your personal information for longer than reasonably necessary.

When we have no ongoing legitimate business need to process personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. We will actively review the personal information we hold and delete it securely, or in some cases, anonymize it when there is no longer a legal, business, or consumer need for it to be retained.

Third Party Sites

This Policy applies only to information collected by the Site.

From time to time, this website may link you to other sites (“Linked Sites”) that are not owned by HBH.  We do not control the collection or use of any information, including PII, which occurs during your visit to the Linked Sites.  Further, we make no representations about the privacy policies or practices of the Linked Sites, and HBH is not responsible for the privacy practices of these Linked Sites.

Be careful when disclosing any of your PII when leaving the Site.  You should review the privacy policies of any third party Linked Sites before you provide any personal information or complete any transaction with such parties. Please contact each third-party provider directly if you have any questions about their privacy policies or the information they require for you to complete any transaction.

Changes to This Policy

We reserve the right to amend this Policy at our discretion and at any time. We may post the policy changes to our website from time to time to reflect customer feedback, changes in our services, and changes in the law.  The updated version will be indicated by a revised “Last updated” date and will be effective as soon as it is posted to our Site. If we make any material changes to this Policy, we will notify you by means of a notice on the Site prior to the change becoming effective. We reserve the right to amend this Policy at our discretion and at any time. We encourage you to periodically review this page for the latest information on our privacy practices and to review our most current Policy. Your continued use of our Site following the posting of changes to this Policy constitutes your acceptance of such changes.

Privacy Rights and Considerations

Residents of the European Economic Area

HBH does not actively target or market to any member state in the European Economic Area (the “EEA”), and does not, to its knowledge, process or control any EEA citizen PII. If you are a resident of the EEA, or are accessing the Site while physically located in the EEA, even if not a resident of the EEA, you have specific rights concerning your PII under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “General Data Protection Regulation” or “GDPR”). Further information and advice about your rights concerning your personal information can be obtained from the supervisory authority in your country that is responsible for monitoring the application of GDPR.

If you are a resident of the EEA, under GDPR, you have the right to:

Request HBH to inform you of or allow you to access the personal data belonging to you that it processes;

Request HBH to change or modify the data it processes about you when you believe the data is inaccurate;

Request HBH to erase any personal information about you that it has collected;

Request HBH to restrict the processing of your personal information under certain conditions;

Request HBH to deliver the personal data it holds about you in a commonly used format and request that such data be transmitted to another controller;

Request HBH to cease processing your personal data through an objection; and

Request HBH not subject you to a decision based solely on automated processing.

If you are a resident in the EEA and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-pl.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you would like to exercise your rights under GDPR, you may contact HBH in accordance with the contact information provided below.

Residents of Canada

If you are a resident of Canada, under the Personal Information Protection and Electronic Documents Act (“PIPEDA”), you have the right to:

Request HBH to provide you with access to the personal information we hold about you;

Request HBH to correct any inaccurate or outdated personal information we hold about you;

Request HBH to delete any inaccurate personal information we hold about you; and

Request HBH to withdraw your consent to any activities for which you have previously consented.

When we collect information from you, you may inform us if you do not wish to be contacted for marketing and market research purposes in accordance with Canadian Anti-Spam Legislation. If you do not want to receive promotional information from us or our representatives, please contact us in accordance with the contact information provided below to update your personal contact preferences.

If you would like to exercise your rights under the PIPEDA, you may contact HBH as outlined below concerning Contacting Data Controller.

Residents of Mexico

If you are a resident of Mexico, under the Federal Law on the Protection of Personal Data Held by Private Parties (“FDPL”) and the Regulations of the Federal Data Protection Law (“FDPL Regulations”), you have the right to:

Request HBH allow you to access the personal data belonging to you that it processes;

Request HBH change or modify the data it processes about you when you believe the data is inaccurate;

Request HBH erase any personal information about you that it has collected;

Request HBH restrict the use and disclosure of your personal information;

Request HBH cease processing your personal data through an objection; and

Request HBH to withdraw your consent to process personal data.

If you would like to exercise your rights under the FDPL Regulations, you may contact HBH as outlined further below.

Children’s Online Privacy Information

CHILDREN ONLINE PRIVACY PROTECTION ACT (“COPPA”) NOTIFICATION

Our Site is not designed for persons under the age of eighteen (18), or such higher age of majority in accordance with the applicable law of your state or country of residence, (the “Age of Majority”). We are not responsible for any access or use of the Site by children or minors under the Age of Majority. No one under the Age of Majority may provide any personal information to or on our Site. We do not knowingly solicit personal information from, or market to, children under the Age of Majority. If you are under the Age of Majority, do not:

use or provide any information on our Site or through any of its features;

make any purchases through our Site;

use any of the interactive or public comment features of our Site; or

provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

By using the Site, you represent that you are at least the Age of Majority, or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site. If we learn we have collected or received personal information from a child under the Age of Majority without verification of parental consent, we will take reasonable measures to promptly delete such data from our records. If you believe we might have any data or information collected from children under the Age of Majority, please contact us at james@thinkbigideagroup.com, 4955 Spring Grove Ave. Cincinnati, OH 45232 or through the use of the Contact Us form on the Site, and we will delete it immediately.

Residents of California

If you are a resident of California, under the California Consumer Privacy Act and California Privacy Rights Act (collectively, “CCPA”), you have the right to:

Request HBH to disclose the categories and specific information that it has collected about you;

Request HBH to delete any personal information about you that it has collected;

Request HBH not to share your personal information at any time (the “right to opt-out”);

Request HBH to correct any inaccurate personal information it maintains about you; and

Request HBH to restrict its use and disclosure of your sensitive personal information.

If you would like to exercise your rights under the CCPA, you may contact HBH as outlined further below. HBH may not discriminate against you if you exercise any of your rights under the CCPA.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us in accordance with the contact information provided below.

Residents of Nevada

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request by contacting us in accordance with the contact information provided below. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Residents of Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, Virginia and Other States with Comprehensive Consumer Privacy Laws

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, Virginia and other states provide (now or in the future) their state residents with rights to:

Request HBH to confirm whether we process your personal information;

Request HBH to allow you to access personal information we hold about you;

Request HBH to delete personal information we hold about you;

Request HBH to correct inaccuracies in your personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah);

Request HBH to provide personal information held about you in a format that is portable, readily usable, and transferable;

Request HBH to allow you to opt-out of personal data processing for targeted advertising (excluding Iowa), sales, or profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah);

Request HBH to either limit or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights, or your rights under any laws in your state of residence, please contact us by using the information below. To appeal a decision regarding a consumer rights request, please contact us in accordance with the contact information provided below.

Contact Information

To request to review, update, delete your personal information, or exercise any of your rights in accordance with this Policy, or if you have any questions regarding this Policy or how to remove or modify your personal information or related consents, please feel free to contact us via any of the following:

HBH Holdings, Inc.

4955 Spring Grove Ave.

Cincinnati, OH 45232

Phone: 513.641.0500

Email: james@thinkbigideagroup.com.

HBH will use commercially reasonable efforts to promptly respond and resolve any problem or question.