SESSSAM EVANS SUPER SYRUP Back to briefing

Legal

Privacy Policy

This policy explains what personal information SESS, Inc. collects through its investor relations site, why we collect it, who we share it with, and how long we keep it. We have written it to describe what this site actually does rather than what a template assumes it does.

01Who we are

SESS, Inc. is a Georgia corporation with its principal place of business in Atlanta, Georgia. In this policy, "SESS", "we", "us" and "our" mean SESS, Inc. "You" means any person who visits this site or submits information through it.

SESS, Inc. is the controller of the personal information described here. For privacy questions, contact us using the details in section 17.

02What this policy covers

This policy covers this investor relations website and the forms it hosts. It does not cover:

03Information we collect

3.1 Information you provide

Investor access request. To request access to investor materials you submit your full name, your email address, your state or territory of residence, and a self certification of whether you are an accredited investor. You may optionally supply a firm or organization name and a LinkedIn profile URL. The state and accreditation fields are required because they are what determine which securities exemption, if any, applies to you.

Investment reservation. If you complete the non-binding investment reservation form, we additionally collect the investment amount tier you select, your indicated timeframe, your preferred method of contact, and, optionally, a telephone number. A reservation is an expression of interest. It is not a purchase, not a commitment, and not binding on you or on us.

Notification list. If you do not qualify under either exemption and you choose to opt in, we record the same details from your access request together with your opt in, so that we may contact you if a future offering is open to you. This is optional and you are not added unless you affirmatively choose it.

Correspondence. If you email us or book a call, we retain that correspondence and the associated scheduling details.

3.2 Information collected automatically

When you submit a form, our server records the following alongside your submission:

IP address
The network address the submission originated from. Used for security, abuse prevention, and as a supporting record of where a submission came from.
Browser user agent
The browser and operating system string your browser reports.
Timestamps
When the form was submitted, and how long it took to complete. Elapsed completion time is used only to identify automated submissions.
Qualification outcome
The exemption determination made at the time you submitted, and any investment limit that applied to you. Retained so the basis of a decision remains auditable even if the rules later change.

3.3 What we do not collect on this site

This site does not collect Social Security numbers, taxpayer identification numbers, bank account details, payment card details, government identification documents, or proof of income or net worth. Accreditation status on this site is self certified and is not verified here. If you proceed toward an actual investment, information of that kind may be collected through the definitive offering process, which is separate from this site and governed by its own terms.

We do not use advertising networks, analytics platforms, session recording, or behavioral tracking on this site.

04How we use your information

We use the information described above only to:

We do not use your information to make automated decisions that produce legal effects about you other than the exemption determination described above, which applies fixed published rules to the state and accreditation values you supply, and which a person can review on request.

05Marketing communications

We do not operate a marketing mailing list from this site and we do not sell or rent your contact details. Communications you receive from us will relate to your specific inquiry, your reservation, the offering, or, where you opted in, a future offering that may be available to you. You can ask us to stop contacting you at any time using the details in section 17, subject to records we are required to retain.

06Who we share information with

We share personal information only in the circumstances below.

6.1 Service providers

We use a small number of third party providers to operate this site. They process information on our behalf and are not permitted to use it for their own purposes:

Amazon Web Services
Hosting, form processing, database storage and outbound notification email. Data is stored in the United States, in the US East (Northern Virginia) region.
Calendly
Scheduling, where you choose to book a call. Calendly receives the details you enter into its booking widget and sets its own cookies. See section 9.
Document sharing provider
Hosting of investor materials. Where the provider requires an email address to open the materials, it receives that address and records your access.
Google Fonts
Typefaces are requested from Google's font service, which receives your IP address and browser user agent as a consequence of serving the request. No form content is sent to it.

6.2 Professional advisers

We share information with our attorneys, accountants, and compliance advisers where reasonably necessary, including in connection with securities filings and reviews.

6.3 Legal and regulatory

We may disclose information where we believe in good faith that disclosure is required by law, regulation, subpoena, court order, or a request from a securities regulator including the Georgia Secretary of State Securities Division, or where disclosure is necessary to protect the rights, property or safety of SESS, Inc., our investors, or others.

6.4 Corporate transactions

If SESS, Inc. is involved in a financing, merger, acquisition, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to the recipient honoring the commitments in this policy.

6.5 We do not sell your information

We do not sell personal information, and we do not share personal information for cross context behavioral advertising, as those terms are used under United States state privacy laws.

07How long we keep it

Investor records are retained permanently unless we tell you otherwise. A record of who requested access to a securities offering, what they certified about their residency and accreditation status, and what determination was made, is a business and compliance record. Deleting it would remove the evidence that we conducted the offering within the terms of the exemptions we rely on. We therefore keep these records for as long as SESS, Inc. exists and for as long afterward as any applicable limitation period or recordkeeping obligation requires.

Correspondence and scheduling records are kept for as long as needed for the purpose they were collected for and then for a reasonable period afterward. Server logs containing IP addresses are retained on a shorter cycle in our hosting provider's log service.

08How we protect it

Information submitted through this site is transmitted over encrypted connections and stored in a database that is encrypted at rest and is not publicly reachable. Access to the stored records is restricted to a small number of people and systems that need it, using individually scoped credentials. The component that writes investor records is permitted to write them and not to delete them.

No method of transmission or storage is completely secure. We cannot guarantee absolute security, and you submit information to us on that understanding.

09Cookies and browser storage

This site sets no cookies of its own and runs no analytics.

After you are granted access, the site stores your access details in your browser's session storage so that the page survives a refresh without asking you to submit the form again. Session storage is confined to that browser tab and is cleared when you close it. It is not transmitted to us and is not readable by other sites.

If you interact with the embedded scheduling widget, that third party may set its own cookies in your browser. Those cookies are controlled by that provider and are governed by its privacy policy, not by this one. You can block or clear them through your browser settings, which may prevent the scheduling widget from working.

Because we do not track you across sites, we take no action in response to browser Do Not Track signals.

10Your choices and rights

You may ask us to:

Depending on where you live, you may have these rights by law, and you may have the right not to be treated differently for exercising them. We extend the choices above to everyone who asks, regardless of residence.

Important limit on deletion

We cannot delete records we are required to keep. Where you requested access to a securities offering, the record of that request, the residency and accreditation you certified, and the determination we made are records supporting our compliance with securities laws. We will honor a deletion request for everything outside that compliance record, and we will tell you plainly what we retained and why.

To make a request, contact us using the details in section 17. We will respond within the time required by applicable law, and generally within 45 days. We may need to ask you for information to verify that the request is genuinely yours, and we will use anything you provide for verification only for that purpose.

If you are unhappy with our response, you may have the right to complain to your state attorney general or another supervisory authority.

11Where your information is held

SESS, Inc. operates in the United States and stores information in the United States. If you access this site from outside the United States, you are transferring your information to the United States, where privacy laws may differ from those in your own country. Do not submit information through this site if you are not willing for it to be processed in the United States.

This offering is directed to residents of the State of Georgia and, on a separate basis, to accredited investors in other United States jurisdictions. It is not directed to persons outside the United States.

12Children

This site is directed to adults and is not intended for anyone under 18. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will delete it.

13Links to other sites

This site links to and embeds services operated by third parties. We are not responsible for the content or privacy practices of those services. Review their policies before providing information to them.

14Security incidents

If we become aware of a breach of security affecting your personal information, we will notify you and any regulator to the extent and within the timeframes required by applicable law.

15Accuracy of what you submit

The residency and accreditation details you provide determine whether we may lawfully communicate with you about this offering. Providing false information on those points affects our ability to rely on the exemptions described in our Disclosures, and may cause us to decline or unwind a proposed investment. Please make sure what you submit is accurate.

16Changes to this policy

We may update this policy. When we do, we will change the "last updated" date at the top. If we make a material change to how we use information we already hold, we will take reasonable steps to tell you directly. Your continued use of the site after an update means you accept the revised policy.

17Contact

Questions, requests, or complaints about this policy or about how we handle your information:

Entity
SESS, Inc., a Georgia corporation
Location
Atlanta, Georgia, United States
Subject line
Please write "Privacy request" so it reaches the right person quickly.