PRISTINE M&L LLC — DATA PRIVACY & PROTECTION POLICY

Effective Date: June 28, 2025

Introduction

Pristine M&L LLC is committed to protecting the privacy and security of personal and confidential information. We have implemented comprehensive administrative, technical, and organizational safeguards to ensure compliance with applicable federal, state, and local privacy regulations. Our commitment to data protection reflects our core values of transparency, responsibility, and ethical business practices.

Scope & Application

This Data Protection Policy applies to all personal information processed by Pristine M&L LLC, including information collected from customers, clients, vendors, business partners, employees, job applicants, and any other individuals interacting with our business.

This policy applies to:

• All employees, contractors, and authorized representatives of Pristine M&L LLC

• All business locations including our operational headquarters at 31 Paterson Avenue, Clifton, New Jersey 07014

• All systems, tools, software, and communication platforms used in company operations

• All collection, use, storage, and disclosure of personal data in physical and electronic formats

Pristine M&L LLC complies with the California Consumer Privacy Act (CCPA) and other state-specific privacy laws applicable to the personal data we process.

Definitions

Personal Data:

Any information that identifies or can be reasonably linked, directly or indirectly, to an individual.

Processing:

Any operation performed on personal data such as collecting, storing, using, transmitting, or deleting.

Data Subject:

Any identifiable individual whose personal data is processed by Pristine M&L LLC.

Data Controller:

Pristine M&L LLC, responsible for determining the purposes and methods of personal data processing.

Confidential Information

Non-public information including business records, financial data, personnel data, and customer information.

Sensitive Information:

Data requiring additional protection, such as government-issued identifiers, financial data, geolocation data, and health-related information.

Data Protection Principles

Pristine M&L LLC follows the following principles:

1. Lawfulness, Fairness & Transparency
   Data is processed legally and individuals are informed of how their information is used.

2. Purpose Limitation
   Data is collected only for specific, legitimate business purposes.

3. Data Minimization
   We limit the amount of data collected and processed to what is necessary.

4. Accuracy
   We maintain accurate data and update information when necessary.

5. Storage Limitation
   Data is retained only for as long as required by business needs or law.

6. Integrity & Confidentiality
   We apply strict safeguards to prevent unauthorized access, loss, or misuse.

7. Accountability
   Pristine M&L LLC maintains policies and oversight to ensure compliance.

Roles & Responsibilities

Company Responsibilities:

• Ensure lawful processing of personal data

• Maintain administrative, technical & physical protective measures

• Provide employee training on privacy and data handling

• Respond to privacy inquiries and legal data requests

• Conduct periodic reviews of this policy and compliance practices

Employee Responsibilities:

All personnel must:

• Follow this policy and all privacy/security procedures

• Access personal data only when required for job duties

• Maintain confidentiality of information

• Report suspected security issues or breaches immediately

Vendor Responsibilities:

Any vendor or third-party service provider processing personal data must:

• Sign a written agreement requiring data protection measures

• Follow lawful processing instructions from Pristine M&L LLC

• Notify us promptly in the event of a security incident

Data Collection & Use

We collect and process personal data necessary to:

• Provide and manage services

• Communicate with customers, clients, and vendors

• Conduct billing, payments, and accounting

• Meet legal and regulatory requirements

• Improve operations, cybersecurity, and customer experience

We do not use personal data for unrelated purposes without additional consent where legally required.

Data Sharing & Third-Party Disclosures

Pristine M&L LLC does not sell personal data.

We may share personal data only when necessary to:

• Process payments or provide services

• Comply with government or legal obligations

• Support company operations through authorized service providers

All third parties must maintain adequate security protections equal to or greater than ours.

International transfers of personal data will include adequate legal safeguards.

Security Measures

We maintain a layered security program including:

Administrative Safeguards

• Access controls and confidentiality obligations

• Employee privacy/security training

• Vendor risk evaluation

• Internal monitoring and audits

Technical Safeguards

• Secure authentication and access permissions

• Encryption in storage and transmission where applicable

• Firewalls, antivirus, and secure network configuration

• Logging and security activity monitoring

Physical Safeguards

• Secure storage for documents

• Limited facility access

• Secure disposal of physical records

Data Retention & Disposal

Personal data is retained only as long as necessary for:

• Business operations

• Legal obligations

• Regulatory compliance

When no longer required, data is permanently destroyed by:

• Secure digital deletion or wiping

• Shredding confidential printed materials

• Removal of access and credentials

Consumer Rights Under CCPA & State Laws

Individuals have the right to request:

• What data we collect and why

• Access to personal information we maintain

• Correction of inaccurate information

• Deletion of personal data where applicable

• A copy of their data in a portable format

• To opt-out of data sharing for targeted advertising

• Protection from discrimination when exercising rights

Identity verification is required before completing requests.

We respond within 45 days or sooner when possible.

Incident Response & Breach Notification

In the event of a data breach:

• The incident will be immediately contained and investigated

• Affected parties and authorities will be notified if required

• Remediation steps will be enforced to prevent recurrence

All employees must report suspected issues immediately.

Submitting Requests & Contact Procedure

Individuals may ask questions or make privacy requests using:

Email: info@itspristineus.com

Phone: 800-417-7969

Address:

Pristine M&L LLC

31 Paterson Avenue

Clifton, New Jersey 07014

United States