Privacy Policy

We take your privacy very seriously and encourage you to read our Privacy Policy carefully. It contains important information about who we are and how we collect, use, disclose, sell, share, store and retain your personal data. The Privacy Policy also explains your rights in relation to personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.

1. Key Terms.

   Here is an explanation of some of the key terms used in this policy:

   We, us, our	The OOMPH brand family of companies Ad Magic Inc.; Ad Magic Print and Play, LLC; Breaking Games, LLC; and Blackbox Systems, LLC.
   Customer Service Representative/Data Protection Officer	[email protected]. Attn: Data Protection Officer
   Personal information	Any information relating to an identified or identifiable individual that possibly includes sensitive personal information(see below), account numbers and credentials.
   Sensitive Personal Information	Personal information revealing account numbers and credentials, precise geolocation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient.

2. Personal Information We Collect About You.

   We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked — directly or indirectly — with a particular consumer or household. The categories of Personal Information and Specific Types of Personal Information Collected are as follows:

   • Identifiers (e.g., a real name, postal address, unique personal identifier, online identifier, email address, account name, social security number, EIN number, or other similar identifiers).
   • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
   • Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
   • Characteristics of protected classifications under California or federal law:
   • Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies).
   • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement).
   • Geolocation data.
   • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

   Be aware that in some instances, if you do not provide the personal information required to provide our products and/or services to you, it may delay or prevent us from providing them to you.

3. How Your Personal Information is Collected.

   We collect personal information from the following categories of sources:

   • You, directly, in person, by telephone, text, or email and/or via our website.
   • Third party with your consent (e.g., your bank.)
   • Advertising networks.
   • Internet service providers.
   • Data analytics providers.
   • Social networks.
   • Publicly accessible sources (e.g., property records).
   • Cookies on our website.
4. How and Why We Use Your Personal Information.

   Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

   • To comply with our legal and regulatory obligations.
   • For the performance of our contract with you or to take steps at your request before entering into a contract.
   • For our legitimate interests or those of a third party.
   • Where you have given consent.
   • A legitimate interest promotes your interests with your consent and when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The table below explains what we use (process) your personal information for and our reasons for doing so:

    

   What we use your personal information for	Our reasons
   To provide our products and/or services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
   To prevent and detect fraud against you or us.	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you.
   Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes	To comply with our legal and regulatory obligations
   Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you.
   Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price.
   Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
   Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures.	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
   Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
   Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract; To comply with our legal and regulatory obligations; For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
   Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
   Marketing our services to: Existing and former customers Third parties who have previously expressed an interest in our services Third parties with whom we have had no previous dealings	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers

   For EEA Data Subjects.

   • The above table does not apply to special category personal information, which we will only process with your explicit consent.  
   • Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or post) about our products AND/OR services, including exclusive offers, promotions or new products AND/OR services.

   We have a legitimate interest in processing your personal information for promotional purposes (see above “How and Why We Use Your Personal Information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.  We will always treat your personal information with the utmost respect and never sell or share it with other organizations outside the Oomph Brand Group for marketing purposes.

5.  You have the right to opt-out of receiving promotional communications at any time by contacting us at [email protected]  or by using the “unsubscribe” link in emails. We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

   Who We Share Your Personal Information With:

   We routinely share personal information with any of the following:

   • Affiliate companies within the OOMPH Brand of families group.
   • Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses, and delivery companies.
   • Other third parties we use to help us run our business, such as marketing agencies or website hosts.
   • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers.
   • Credit reporting agencies.
   • Our insurers and brokers.
   • Our bank(s).

   We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on our service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, such as those related to our ESG program, retail accounts or our accounting processes.  We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

6. Personal Information We Shared.

   In the preceding 12 months, we have shared the following categories of personal information, which include characteristics of protected classifications under California or federal law such as:

   • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name.
   • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, address, telephone number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information.
   • Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies).
   • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement).
   • Geolocation data.
   • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
7. Categories of Personal Information We Disclosed for a Business Purpose.

   In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

   • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, or other similar identifiers).
   • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, address, telephone number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information.
8. Characteristics of protected classifications under California or federal law.
   • Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies).
   • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
   • Geolocation data.
   • Audio, electronic, visual, or similar information.
   • Professional or employment-related information.
   • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
   • Sensitive personal information.
9. How Long Your Personal Information Will Be Kept.

   We will keep your personal information and when it is no longer necessary for us to retain your personal information, we will delete or anonymize it.

10. California Consumers.

    Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise, free of charge:

    Disclosure of Personal Information We Collect About You	You have the right to know, and request disclosure of: • The categories of personal information we have collected about you, including sensitive personal information. •The categories of sources from which the personal information is collected. • The categories of third parties to whom we disclose personal information, if any. •The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained. Again identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information. Provide the personal information to you more than twice in a 12-month period.
    Disclosure of Personal Information Shared, or Disclosed for a Business Purpose	In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know: • The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared. • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose You have the right to opt-out of the sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sharing of your personal information, we will refrain from sharing your personal information unless you subsequently provide express authorization to share.  To opt-out of the sale or sharing of your personal information, click here: Do Not Sell or Share My Personal Information
    Right to Limit Use of Sensitive Personal Information	You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: • Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services. •Perform the following services: (1). Help ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes. (2) Be used for short-term, transient purposes, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business or if personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business; 3) Perform services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and– As authorized by further regulations, you have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. To limit the use of your sensitive personal information, click here: “Limit the Use of My Sensitive Personal Information”
    Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records. Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort. Please note that we may not delete your personal information if it is reasonably necessary to: (1) Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us. (2) Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes. (3) Debug to identify and repair errors that impair existing intended functionality. (4) Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law. (5) Comply with the California Electronic Communications Privacy Act. (6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent. (7) Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us. (8) Comply with an existing legal obligation. (9) Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
    Right of Correction	If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
    Protection Against Retaliation	You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: (1) Deny goods or services to you. (2) Charge different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties. (3) Provide a different level or quality of goods or services to you. (4) Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

11. EEA Data Subjects: Your Rights Under the EU GDPR.
    

    Right to Be Informed	The right to know or be notified about the collection and use of your personal information
    Right to Access	The right to be provided with a copy of your personal information (the right of access)
    Right to Rectification	The right to require us to correct any mistakes in your personal information
    Right to be Forgotten	The right to require us to delete your personal information in certain situations
    Right to Restriction of Processing	The right to require us to restrict processing of your personal information in certain circumstances, e.g., if you contest the accuracy of the data
    Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party in certain situations
    Right to Object	The right to object at any time to your personal information being processed for direct marketing (including profiling) In certain other situations to our continued processing of your personal information, e.g., processing carried out for our legitimate interests.
    Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

    For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the EU General Data Protection Regulation.

    Where Your Personal Information is Held.

    Information may be held at our offices and those of our affiliates. third-party agencies, service providers, representatives and agents as described above (See above: “Who We Share Your Personal Information with”).  Some of these third parties may be based outside the EEA. For more information, including on how we safeguard your personal information when this occurs:

    • Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the EEA, such as with our offices and services providers, which are or may be located outside the EEA or where there is an international dimension to the services we are providing to you.  These transfers are subject to special rules under European and UK data protection law.  We will be transferring your information to the USA, where our companies are headquartered.  Additionally, depending upon the Services you ask us to perform on your behalf, we may be transferring your personal information to our third-party service providers, who are diversely located in other countries, which may or may not have the same data protection laws as the United Kingdom and EEA. We will, however, endeavor to ensure the transfer complies with data protection law and all personal information will be secure.
    • Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
    • Filing a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.  The GDPR also gives you right to lodge a complaint with a supervisory authority, in the European Union (or EEA) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
12. How to Exercise Your Rights.

    If you would like to exercise any of your rights as described in this Privacy Policy, you can do so via email to: [email protected]. You may also call us at 973-448-1766. Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period. If you choose to contact us directly, you will need to provide us with:

    • Enough information to identify you (e.g., your full name, address and customer or matter reference number).
    • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill).
    • A description of what right you want to exercise and the information to which your request relates

    We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection your request will be used solely for the purposes of verification.

    Changes to This Privacy Notice. This privacy notice was published and updated on July 1, 2025. We may change this privacy notice from time to time. When we do, we will inform you via website update.