Privacy Policy

Elite Poke Tribe LLC (doing business as XPcollect)

Effective Date: 6/13/2026 · Last Updated: 6/13/2026

1. Introduction

Elite Poke Tribe LLC, doing business as XPcollect (“XPcollect,” “we,” “us,” or “our”), respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains what information we collect, how we use and share it, and the choices and rights you have regarding your information.

This Policy applies to information we collect through:

• Our websites, including www.xpcollect.com and XPro.xpcollect.com and any other sites or applications that link to this Policy (collectively, the “Sites”);
• Our online store and membership platform;
• Our physical retail location(s) and trade-show or convention appearances;
• Our sales activity on third-party marketplaces and platforms, including eBay and TikTok Shop / TikTok live commerce; and
• Our communications with you by email, text message, phone, or social media.

By using our Sites or services, or by purchasing from us through any channel, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, please do not use our Sites or services.

2. Information We Collect

We collect personal information in three ways: information you provide directly, information collected automatically, and information we receive from third parties.

2.1 Information You Provide Directly

• Account and profile information: name, username, password, and membership or subscriber status.
• Contact information: email address, mailing/shipping address, billing address, and phone number.
• Order and transaction information: items purchased, order history, order value, and shipping details.
• Payment information: billing details and the last four digits of a payment card. Full payment-card numbers are processed by our third-party payment processors and are not stored on our systems. (See Section 5.)
• Communications: information you provide when you contact customer service, post in chats during live streams, leave reviews, enter sweepstakes or giveaways, or otherwise correspond with us.
• Marketing preferences: your email/SMS subscription choices and interests.

2.2 Information Collected Automatically

When you use our Sites, we and our service providers may automatically collect:

• Device and technical data: IP address, browser type, operating system, device identifiers, and language settings.
• Usage data: pages viewed, links clicked, products viewed or added to cart, time spent, referring/exit pages, and session activity.
• Cookies and similar technologies: see Section 6 for details.

2.3 Information From Third Parties

• Marketplaces and platforms:order, fulfillment, and limited customer information from eBay, TikTok Shop, and similar platforms through which you transact with us. Each platform’s own privacy practices govern data they collect directly.
• Payment processors and fraud-prevention services: transaction confirmation and fraud/risk signals.
• Shipping and logistics providers: delivery status and address verification.
• Analytics and advertising partners: audience and measurement data.

3. How We Use Your Information

We use personal information for the following purposes:

• To create and manage your account and membership, and to authenticate you.
• To process, fulfill, and ship your orders, and to manage returns, exchanges, and refunds.
• To process payments and prevent, detect, and investigate fraud and other unauthorized or unlawful activity.
• To operate, maintain, secure, and improve our Sites, products, and services.
• To provide customer support and respond to your inquiries across our channels.
• To send transactional communications (order confirmations, shipping updates, receipts, and service notices).
• To send marketing and promotional communications, where permitted, and to administer giveaways, sweepstakes, drops, and similar promotions.
• To personalize your experience, including product recommendations and subscriber/member pricing and access.
• To analyze usage and trends and to conduct internal research and analytics.
• To comply with legal obligations, enforce our terms, and protect the rights, property, and safety of XPcollect, our customers, and others.

We may use automated tools and technologies, including artificial intelligence, to support customer service, inventory, fraud detection, and operational tasks. We do not use such tools to make decisions that produce legal or similarly significant effects about you without appropriate review and disclosure where required by law.

4. Legal Bases for Processing

Where applicable law requires a legal basis for processing your personal information, we rely on one or more of the following: performance of a contract with you (such as fulfilling an order); your consent (such as for certain marketing or the processing of sensitive data); compliance with a legal obligation; and our legitimate interests in operating, securing, and improving our business, provided those interests are not overridden by your rights.

5. How We Share Your Information

We do not sell your personal information for money. We may share personal information in the following circumstances:

• Service providers: companies that perform services on our behalf, such as payment processing, shipping and logistics, hosting and IT, email/SMS delivery, analytics, customer support, and fraud prevention. These providers are authorized to use your information only as necessary to provide services to us.
• Marketplaces and platforms:when you purchase from us through eBay, TikTok Shop, or similar platforms, information is shared as needed to complete and support your transaction, subject to those platforms’ own policies.
• Payment processors: to complete your transactions securely.
• Business transfers: in connection with a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, your information may be transferred as a business asset.
• Legal and safety: when we believe disclosure is required by law, regulation, legal process, or governmental request, or is necessary to protect rights, property, or safety.
• With your direction or consent: when you ask us to share your information or otherwise consent.

Some of our sharing for analytics and advertising may be considered a “sale” or “sharing for targeted advertising” under certain state laws. See Section 8 for your opt-out rights.

6. Cookies and Tracking Technologies

We and our partners use cookies, pixels, tags, local storage, and similar technologies to operate the Sites, remember your preferences, analyze traffic, secure your sessions, and support marketing.

• Essential cookies are necessary for the Sites to function (for example, maintaining your shopping cart and login).
• Analytics cookies help us understand how the Sites are used.
• Advertising/targeting cookies help deliver and measure relevant advertising.

You can control cookies through your browser settings and, where offered, through our cookie-preference tools. We honor recognized universal opt-out mechanisms, such as the Global Privacy Control (GPC), as a valid request to opt out of the sale of personal data and processing for targeted advertising where required by law. Disabling some cookies may affect Site functionality.

7. Data Retention

We retain personal information for as long as needed to fulfill the purposes described in this Policy, including to provide our services, maintain your account, comply with our legal and tax obligations, resolve disputes, prevent fraud, and enforce our agreements. When information is no longer needed, we take reasonable steps to delete, de-identify, or securely store it. Retention periods vary depending on the type of information and applicable legal requirements.

8. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights regarding your personal information. We honor these rights as required by applicable law.

8.1 Rights Available to Eligible Consumers

• Right to know / access: to confirm whether we process your personal information and to obtain a copy of it.
• Right to correct: to correct inaccurate personal information.
• Right to delete: to request deletion of your personal information, subject to legal exceptions.
• Right to data portability: to obtain your personal information in a portable, readily usable format.
• Right to opt out: to opt out of the sale of personal information, processing for targeted advertising, and certain profiling that produces legal or similarly significant effects.
• Right to limit sensitive data: to limit or withhold consent for the processing of sensitive personal information.
• Right to non-discrimination: to not be discriminated against for exercising your rights.
• Right to appeal: to appeal our decision regarding a privacy request (see below).

8.2 New Jersey Residents

XPcollect is based in New Jersey. Under the New Jersey Data Privacy Act, eligible New Jersey residents have the rights described above, including to access, correct, delete, and obtain a portable copy of their personal data, and to opt out of its sale, of targeted advertising, and of certain profiling. We obtain your consent before processing sensitive data, and we recognize universal opt-out signals such as the Global Privacy Control. We respond to verified requests within 45 days (extendable by an additional 45 days where permitted) and provide an appeal process described below.

8.3 California Residents

If you are a California resident, you have rights under the California Consumer Privacy Act, as amended, including the rights to know, access, correct, delete, opt out of sale/sharing, and limit the use of sensitive personal information, as well as the right to non-discrimination. We do not knowingly sell the personal information of consumers under 16 years of age without the required consent.

8.4 Other State Residents

Residents of other U.S. states with comprehensive privacy laws may have similar rights. We honor the rights granted to you under the privacy law applicable to your state of residence.

8.5 How to Exercise Your Rights

To submit a request, contact us using the details in Section 13, or use any request mechanism we make available on our Sites. We will take reasonable steps to verify your identity before fulfilling your request, which may require you to confirm information we already hold about you. You may use an authorized agent to submit a request where the law permits; we may require proof of authorization.

8.6 Appeals

If we decline to take action on your request, you may appeal by contacting us using the details in Section 13 with the subject line “Privacy Appeal.” We will respond to your appeal within the timeframe required by applicable law and explain our decision. If your appeal is denied, you may contact your state Attorney General to submit a complaint.

9. Marketing Communications and Choices

• Email:you may opt out of marketing emails at any time by clicking the “unsubscribe” link in any marketing email or by contacting us. You will continue to receive transactional messages related to your orders and account.
• SMS/text: if you opt in to text messages, you may opt out by replying STOP to any message. Message and data rates may apply.
• Mobile/browser notifications and cookies: you can manage these through your device or browser settings as described in Section 6.

10. Children’s Privacy

Our Sites and services are intended for a general audience and are not directed to children under 13, and we do not knowingly collect personal information from children under 13 in violation of the Children’s Online Privacy Protection Act (COPPA). If you are under 13, please do not use our Sites or provide any personal information. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information.

For consumers between the ages of 13 and 17, where required by applicable law (including the New Jersey Data Privacy Act), we obtain consent before processing personal data for targeted advertising, sale, or certain profiling. If you are a parent or guardian and believe your child has provided us with personal information, please contact us using the details in Section 13.

11. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and disclosure. These measures include, where appropriate, encryption in transit, access controls, secure handling of payment data by our processors, and ongoing security review. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.

12. Additional Disclosures

• Third-party links: our Sites and live streams may link to or be hosted on third-party platforms and websites. We are not responsible for the privacy practices of those third parties, and we encourage you to review their policies.
• International users: we are based in the United States and our services are intended for U.S. customers. If you access our Sites from outside the United States, you understand your information will be processed in the United States, where data-protection laws may differ from those in your jurisdiction.
• Do Not Track:some browsers offer a “Do Not Track” signal. Because there is no common industry standard for responding to these signals, we currently respond to recognized universal opt-out mechanisms such as the Global Privacy Control as described in Section 6.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact us:

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will revise the “Last Updated” date above and, where required by law, provide additional notice (such as by email or a notice on our Sites). Your continued use of our Sites or services after the effective date of an updated Policy constitutes your acknowledgment of the changes.

This template is provided for informational purposes only and does not constitute legal advice. Privacy laws vary by jurisdiction and change over time. You should have this document reviewed and customized by a qualified attorney before publishing it, and confirm it accurately reflects your actual data practices.