Electronic Privacy Agreement
Last Updated: March 25, 2026
This Electronic Privacy Agreement (the “Privacy Agreement”) governs the collection, use, processing, storage, disclosure, and protection of information in connection with access to and use of the GoldSteel Platform (the “Platform”) operated by Kelley Creations LLC, a Georgia limited liability company (“Company”). By accessing or using the Platform, End User agrees to be bound by this Privacy Agreement.
1. SCOPE AND APPLICATION
1.1 This Privacy Agreement applies to all information collected by or through the Platform, including information provided by End User and information collected automatically through use of the Platform.
1.2 This Privacy Agreement applies solely to commercial business use of the Platform and does not create consumer privacy rights.
2. INFORMATION COLLECTED
2.1 Company may collect, process, and store the following categories of information:
(a) Account information, including names, business identifiers, email addresses, phone numbers, and login credentials;
(b) Transactional and inventory data entered into or generated through the Platform;
(c) Technical data, including IP addresses, device identifiers, browser type, operating system, access times, and usage patterns;
(d) System activity data, logs, audit trails, and interaction records;
(e) Communications between End User and Company; and
(f) Any other data submitted, uploaded, or transmitted by End User through the Platform (“User Data”).
3. AUTOMATED COLLECTION AND TRACKING
3.1 Company may use cookies, tracking technologies, device fingerprinting, and log analysis tools to monitor usage and performance of the Platform.
3.2 Company may collect metadata, behavioral analytics, and system interaction data for security, compliance, and operational purposes.
3.3 End User consents to all such monitoring, collection, and analysis.
4. USE OF INFORMATION
4.1 Company may use collected information for any lawful purpose, including:
(a) providing, maintaining, and improving the Platform;
(b) processing transactions and managing accounts;
(c) enforcing this Agreement and protecting Company’s rights;
(d) detecting, preventing, and investigating fraud, unauthorized access, or misuse;
(e) conducting audits, compliance reviews, and internal investigations;
(f) developing new features, services, or technologies; and
(g) complying with legal obligations.
5. DISCLOSURE OF INFORMATION
5.1 Company may disclose information:
(a) to affiliates, contractors, service providers, and advisors;
(b) in connection with mergers, acquisitions, financing, or asset sales;
(c) to comply with legal process, governmental requests, or regulatory requirements;
(d) to enforce this Agreement or protect Company’s rights, property, or security;
(e) to investigate suspected violations, fraud, or unlawful conduct; and
(f) as otherwise permitted by law.
5.2 Company does not sell personal information as that term is commonly defined under U.S. privacy laws.
6. DATA SECURITY
6.1 Company implements commercially reasonable administrative, technical, and physical safeguards to protect information.
6.2 Notwithstanding the foregoing, no system is secure, and Company does not guarantee the security of any information.
6.3 End User is solely responsible for maintaining the confidentiality and security of its credentials and systems.
7. DATA RETENTION
7.1 Company may retain information for as long as Company deems necessary for business, legal, regulatory, or enforcement purposes.
7.2 Company may retain logs, records, and related data for a minimum of three (3) years or longer at Company’s discretion.
8. DATA PROCESSING AND LOCATION
8.1 Information may be processed and stored in the United States or any other jurisdiction selected by Company.
8.2 End User consents to cross-border transfer, storage, and processing of information.
9. NO CONFIDENTIALITY OR FIDUCIARY OBLIGATION
9.1 Except as expressly stated in the Terms of Service, Company has no obligation to treat User Data as confidential.
9.2 Company is not a fiduciary, custodian, or trustee of any data.
10. COMPLIANCE AND INVESTIGATIONS
10.1 Company may monitor, review, and analyze all data and activity on the Platform for compliance and enforcement purposes.
10.2 Company may access, preserve, and disclose information where reasonably necessary to investigate violations or protect Company’s interests.
11. USER RESPONSIBILITIES
11.1 End User represents and warrants that it has all necessary rights, consents, and authority to provide User Data to Company.
11.2 End User is solely responsible for compliance with all applicable privacy, data protection, and security laws relating to its data.
11.3 End User shall not upload or process data in violation of any law or third-party rights.
12. LIMITATION OF LIABILITY
12.1 Company shall not be liable for unauthorized access, data breaches, loss of data, or security incidents, except to the extent required by applicable law.
12.2 End User assumes all risk associated with transmission and storage of data.
13. MODIFICATIONS
13.1 Company may modify this Privacy Agreement at any time in its sole discretion.
13.2 Continued use of the Platform after modification constitutes acceptance of the revised Privacy Agreement.
14. GOVERNING LAW AND ENFORCEMENT
14.1 This Privacy Agreement shall be governed by the laws of the State of Georgia.
14.2 All disputes shall be resolved in accordance with the dispute resolution provisions set forth in the Terms of Service Agreement.
15. INTEGRATION
15.1 This Privacy Agreement is incorporated into and made part of the GoldSteel Terms of Service Agreement.
15.2 In the event of any conflict, the Terms of Service Agreement shall control.
16. SURVIVAL
16.1 All provisions of this Privacy Agreement that by their nature should survive termination shall survive, including without limitation provisions relating to data use, disclosure, security, retention, compliance, limitation of liability, and enforcement.