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This Privacy Policy describes how Brass International LLC (the “Site” or “We” or “Our”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

1. Contact

After reviewing this policy, if you have additional questions, want more information about our privacy practices, or would like to submit a complaint, please contact us by e-mailing us at, Attn: Privacy Policy.

2. Collecting Personal Information

When you visit our Site and use our services, whether as  a Guest, a Registered Account holder, or as a participant in a discount program, you will be providing Personal Information about yourself and household. Personal Information, in general, is  information that can identify you. Personal Information would include your name, email address, cell number, records of product purchases, internet browsing history, etc. A more detailed  definition of Personal Information can be found at Section 9, below (“Your Rights: California Consumer Privacy Rights  Act of 2023). Personal Information may also  be collected about your device, your interaction with the Site, and purchase history. We may also collect additional information from you when  you contact us for customer support.

Below, we identify categories of information that we commonly would be collecting from you and the reasons for collecting it.

  • Device information
    • Purpose of collection: To load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
    • Source of collection: This information is collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
    • Disclosure for a business purpose: This  information is also shared with our processor Shopify, and other third-party service providers: Google, Klaviyo, our Shipping Providers, and all other third-party services that  we need to support the operation of our site and to facilitate advertising operations.
    • Personal Information collected: Other types of Personal Information we collect are  information concerning your web browser, IP address, the time zone you are in, cookie information, what sites or products you view, search terms you have used to find our Site, and how you interact with the Site.
  • Information Collected for Purposes of Advertising
    • Email Marketing: You should understand that by entering your email address into our customer information form and submitting it, you automatically are consenting to receive email messages from us, among other things, concerning changes in our policies, promotions, products you may be interested in, and cart reminders. To opt-out of this program, you may click the unsubscribe icon at the end of an  email we send you. If you have any trouble doing this, please email us at, Attn: Email Opt-Out.

 Mobile Messaging Program: For those customers who opt to participate in our mobile messaging service, you will receive notices via text messages, among other things, concerning promotions as well as the status of deliveries. Opting into this program is voluntary but if you would like to opt-out, you may click the STOP icon at the end of a text we send you. If you have any trouble doing this, please email us at, Text Opt-Out. For additional information concerning our Mobile Messaging Program, please see Annex A to this Privacy Policy

    • Direct Mail Program: For those customers who have been entered into our direct mail service by way of your activity on our site, you will receive promotions via direct mail. The terms governing our direct mail service and how to opt-out of the program is  detailed at Annex B to this Privacy Policy.
  • Order information
    • Purpose of collection: To provide products or services to you in fulfillment of your product order, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you about your purchases, screen our orders for potential risk or fraud, and, when in line with the preferences you have shared with us, provide you with information or advertising about related products or services you might be interested in purchasing.
    • Source of collection: This information is collected from you by way of your submission of information about yourself via  our information form or through your ordering merchandise through our Site.
    • Disclosure for a business purpose: This information is shared with our processor Shopify as well as  our other service providers,  Google, Klaviyo, our Shipping Providers, and all other third-party services needed to maintain   the operation of our Site and facilitate advertising.
    • Personal Information collected: The type of Personal Information we would collect by way of your ordering merchandise through our site would  include, your name, billing address, shipping address, payment information, email address, and phone/cell number.
  • Customer support information
    • Purpose of collection: To be able to resolve your customer service inquiries.
    • Source of collection: This  information would be collected from you while you are engaged with our customer service facilities.
    • Disclosure for a business purpose: The purpose of collecting this  information would be to resolve your customer inquiry, improve our products and services, and learn about technical problems you may have encountered with our site which would allow us to resolve those problems for your benefit and the benefit of other customers.
    • Personal Information collected: The type of Personal Information we would  be collecting would include, your name, address, product you want to purchase, or have purchased, order number, and other information collected from you via special instructions you may advance to us that could identify you or your household.
    • Purpose of collection: To provide customer support.
    • Disclosure for a business purpose: Such Personal  Information may be disclosed to our staff, supporting technology platforms, shipping providers, or other third parties needed to understand the bases for your request and to solve the problem you present.

3.  Minors

Our Site and Apps are not intended to be used by individuals under the age of majority (“minors”), as defined by applicable law, unless they have permission from their legal parent or guardian and their legal parent or guardian agrees to subscribe to our Terms of Use, this Privacy Policy, and any applicable terms of sale. In many jurisdictions, the age of majority is 18 years old.

We do not intend to collect Personal Information from Minors.

Our Site, Apps, and the online services we provide are not directed to children under the Age of 13 year’s old.

If you are the parent or guardian of a minor child, including a child under the age of 13 years, and believe they have provided us with Personal Information, please contact us at the email address designated above to request that such information be deleted.

4. Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our purchase order contracts with you, as described above. For example:

  • We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here:
  • We may also need to share your Personal Information with third-party vendors in order to address technical problems and enhance the functioning of our site, but understand that our third-party vendors may, in turn, need to disclose your Personal  Information to their vendors, about whom we may have no knowledge and over whom we have no control.
  • We may also need to share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or otherwise to protect our rights.

5. Behavioral Advertising

As described above, we may use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

  • We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: You can also opt-out of Google Analytics here:
  • We may share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and, in some cases, through the use of cookies or other similar technologies (which you may consent to, depending on your location).
  • We use Shopify Audiences to help us show ads on other websites with our advertising partners to buyers who made purchases with other Shopify merchants and who may also be interested in what we have to offer. We also share information about your use of the Site, your purchases, and the email address associated with your purchases with Shopify Audiences, through which other Shopify merchants may make offers you may be interested in.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at

Notwithstanding the foregoing explanation about how we may use your Personal Information to enhance our targeted advertising, if you do not want us to use your Personal Information for purposes of targeted advertising, you may opt-out of our advertising program by contacting us using the Contact information provided above or by contacting the relevant platforms, as follows:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:

6. Using Your Personal Information

As we have discussed, we use your Personal Information to be able to provide our services to you, including, but not limited to, offering products for sale, fulfilling purchase orders by allowing us to process payments and shipping, and keeping you up to date on new products, services, and offers.

7. Retention

When you place an order through our Site, we will retain your Personal Information for our records unless and until you ask us to delete this information. For more information on your right of deletion under applicable law, please see section 9, below, concerning the California Consumer Privacy Rights Act.

8. Automatic decision-making

Under applicable law, you may have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal impact on you or otherwise significantly affects you.

Be on notice, that we do not engage in fully automated (algorithmic) decision-making that should have a legal impact on you or should otherwise significantly affect you.

To the extent our processor, Shopify, may use limited automated decision-making, it is intended only to prevent fraud and should not have any legal impact or otherwise significantly affect you.

Services that include elements of automated decision-making may include:

  • Temporary blacklist of IP addresses associated with repeated failed transactions. This blacklist persists for a limited number of hours.
  • Temporary blacklist of credit cards associated with blacklisted IP addresses. This blacklist persists for a limited number of days.
  • Permanent blacklist of IP address associated with fraud or other chronic violations of our Terms of Use.

9. Your Rights: California Consumer Privacy Rights Act of 2023 (“CCPRA”)

If you are a California resident, your Personal Information is protected under the California Consumer Privacy Rights Act of 2023 (“CCPRA”). 

Under California’s CCPRA, Personal Information is information that identifies, concerns, or is associated with a particular consumer or household.

Examples of Personal Information are your name, email address, records of product purchases, internet browsing history, geolocation information, fingerprints, and any information from which one can draw inferences about your consumer preferences and characteristics.

Sensitive Personal Information includes, but is not limited to, government assigned identification numbers, like social security numbers, account log-in information (e.g. passwords, other credentials like responses to security questions), account numbers, debit and credit card numbers, information tracking your precise geolocation, biometric  information, information concerning your health, sex life, sexual  orientation, or information about racial or ethnic origin, religious or philosophical  beliefs, or union membership.

Personal Information and Personal Sensitive information, however, shall not include information about you that is publicly available. Personal Information can be made publicly available by you, among other things, by your publishing information about yourself on social media.

Unless otherwise distinguished, Personal Information and Personal Sensitive Information will be referred to in this Privacy Policy, collectively, as “Personal Information.”

If you are a resident of California, you have the right (i) to find out what  specific Personal Information we have  concerning you, (ii) to find out what Personal Information we have shared with Third Parties, (iii) to limit the use and disclosure of Personal Information, (iv) to port your personal information to a new service, (v) to ask that your Personal Information be corrected, updated, or deleted, (vi) to opt-out of the sale  and  sharing of your Personal Information, and (vii) to not be discriminated against for exercising your rights under the CCPRA. If you would like to exercise any of these rights, please contact us at, Attn: Privacy Policy.

The Right to Know:  You can request us to disclose to you the following information about your Personal Information: (i) categories and/or specific Personal Information about you that we  have collected, including the categories of sources of that Personal Information, (ii) the purposes for which our business uses  your Personal Information, (iii) the categories of third parties to whom our business has disclosed your Personal Information, and (iv) the categories of information that our business sells to third parties (if any).

The Right to Delete: Except where applicable law provides otherwise, you can request that our business (including its service  providers) delete your Personal Information.

The Right to Correct. You can ask our business to correct  Personal Information about you that is inaccurate.

The Right to Opt-Out of Sale or Sharing: You may request that  our business cease the selling and/or sharing of your Personal Information, including via a user-enabled privacy control. If you Opt-Out of the selling and/or sharing of your personal Information, our business shall be thereafter prohibited from selling or sharing your Personal Information until you later provide the authorization for us to do so.

The Right to limit use and disclosure of Sensitive Personal Information. You can instruct our business only to use your Sensitive Personal Information for limited purposes, such as the ability to access our Service.

The Right not to be discriminated against. Should you exercise any of your rights to protect your Personal Information, we are prohibited from taking any retaliatory action against you, such as limiting your Service, delaying the processing of your orders, or otherwise taking any actions to inhibit or degrade your user experience. 

We do not sell Personal Information to Third Parties. It is our current policy not to sell the Personal Information of our customers to Third Parties.

Should you believe that  your rights have been violated under California’s Consumer Privacy Rights Act, you may contact the California Privacy Protection Agency (

For more information about the California Consumer Privacy Rights, see

 10. Your Rights:  Residents of the European Economic Area

Pursuant to the General Data Protection Regulation (“GDPR”), promulgated by the Commission of the European Union, if you are a resident of the European Economic Area, we process your Personal Information under the following lawful bases:

  • Your consent;
  • The performance of the contract between you and the Site;
  • Compliance with our legal obligations;
  • To protect your vital interests;
  • To perform a task carried out in the public interest;
  • For our legitimate interests, which do not override your fundamental rights and freedoms.

Pursuant to the GDPR, you have the right (i) to access the Personal Information we hold about you, (ii) to port it to a new service, (iii) to restrict the use of your Personal Information for certain purposes, (iv) to object to our processing your Personal Information for certain purposes, (v) to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us at, Attn: Privacy Policy.

Be advised that we use third-party processors to store your personal information and do not hold the data ourselves. Our third-party processor  is, which, in turn, may use sub-processors to facilitate the transfer of Personal Information internationally. For more information on Shopify and its use of processors and sub-processors, please see

11. Your rights if you reside in jurisdictions outside the United States and European Economic Area

Should you reside in a jurisdiction outside the United States and the European Economic Area, such as Canada, we shall apply the GDPR standards to the how we receive, process, hold, and manage (altogether, “manage”) your Personal Information, except that should your Personal Information be managed by our third-party processor, you should consult that processor’s privacy policy. We use as a third party-processor to manage Personal Information uploaded to our Site and Apps. To review’s Privacy Policy, please see

12. You are Prohibited from Misrepresenting Yourself

Be advised that pursuant to our Terms of Use, parties who intend on using are platform are prohibited from submitting to us false user data, including information misrepresenting their identity, including, but not limited to, name, residence,  and  shipping information.    

 13. Cookies

A cookie is a small amount of information that is automatically downloaded to your computer or device when you visit our Site. We use a number of different kinds of cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website. For instance, information collected via a cookie can tell us whether a visitor is a first time or frequent visitor to our site.

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies could negatively impact your user experience and prevent you from being able to access parts of our website.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies by changing your browser controls, often found within your browser’s “Tools” or “Preferences” menu. More information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: and!/.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, we refer you back to Section 5 hereof (Behavioral Advertising). Should you continue to have questions about opting out of targeted advertising, please contact us using the Contact information supplied above.

14. Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time with or without notice in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

16. Complaints

Unless otherwise noted above, if you would like to lodge a complaint with a government authority concerning our protection of your Personal Information and/or compliance with this  Privacy Policy under applicable law, it is recommended that you contact the relevant consumer privacy rights authority or consumer protection authority or Attorney General’s Office in your state or territory.

April 4, 2023


Terms Governing Brass’s Mobile Messaging Program

The Brass International LLC mobile messaging service (the "Service") is operated by Brass International LLC (“Brass International LLC”, “we”, or “us”). Your use of the Service constitutes your agreement to these terms and conditions (“Mobile Terms”). We may modify or cancel the Service or any of its features without notice. To the extent permitted by applicable law, we may also amend these Mobile Terms at any time. Your continued use of the Service following the effective date of any such modification shall constitute your acceptance of such changes.

By opting into our mobile messaging service, which permits us to send you SMS/text messages, you agree to receive recurring SMS/text messages from and on behalf of Brass International LLC through your wireless provider to the mobile number you provided, even if your mobile number is registered on a state or federal Do Not Call list. Text messages may be sent using an automatic telephone dialing system or other technology. Service-related messages may include updates, alerts, and information (e.g., order updates, account alerts, etc.). Promotional messages may include promotions, specials, and other marketing offers (e.g., cart reminders).

You understand that you do not have to opt into this program in order to make any purchases or to be able to access our website. Your participation in this program is completely voluntary.

We do not charge for the Service, but you are responsible for all charges and fees associated with text messaging imposed by your wireless provider. Message frequency varies. Message and data rates may apply. Check your mobile plan and contact your wireless provider for details. You are solely responsible for all charges related to SMS/text messages, including charges from your wireless provider.

If you have subscribed to other Brass International LLC mobile message programs and wish to cancel, except where applicable law requires otherwise, you will need to opt out separately from those programs by following the instructions provided in their respective mobile terms.

We may change any short code or telephone number we use to operate the Service at any time and will notify you of these changes. You acknowledge that any messages, including any STOP or HELP requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honoring requests made in such messages.

The wireless carriers supported by the Service are not liable for delayed or undelivered messages. You agree to provide us with a valid mobile number. If you obtain a new mobile number, you will need to sign up for the program with your new number.

To the extent permitted by applicable law, you agree that we will not be liable for failed, delayed, or misdirected delivery of any information sent through the Service, any errors in such information, and/or any action you may or may not take in reliance on the information or Service.

The use and protection of your personal information collected via this Service, including your cell number, name, and address, shall be governed by our Privacy Policy, which is included by reference herein and made a part of this Annex A.


Terms Governing Brass’s Direct Mail Program

Our Direct Mail Program involves our using a third-party service to match browser cookies to your mailing address. We then use another company to send special offers to you through regular mail on our behalf. Our Company never receives or stores any of this information.

A “cookie” is a small file stored on your device that is sent by websites, mobile apps, and advertisements that you access. These tiny files are stored on your device to remember your preferences to improve your experience while browsing. For more information on what cookies are, how they are used, and how you may be able to filter or block cookies, please refer to Section 11 of our Privacy Policy, which is included by reference herein and made a part of this Annex B.

We may modify or cancel this Program or any of its features without notice. To the extent permitted by applicable law, we may also amend these terms at any time. Your continued use of the Service following the effective date of any such modification shall constitute your acceptance of such changes.

You understand that you may be entered into our Direct Mail program automatically based on your activity on our site. Should you want to opt out of this program, please contact us by email at, Attn: Direct Mail Opt-Out. Upon receiving your instruction, we will direct our marketing company not to send you any further direct mailings.

Participating in our Direct Mail Program is not a condition to your being able to access our site to browse and/or purchase products.