Privacy Policy
1. Who We Are and What This Policy Covers
Sutpen’s Hundred, LLC (“Sutpen’s Hundred,” “we,” “us,” or “our”) is a federally licensed firearms dealer located in Phoenix, Arizona. This Privacy Policy explains what information we collect, how we use it, who we share it with, and what choices you have.
This policy applies to:
- Our website at www.sutpenshundred.com
- Our online store at shop.sutpenshundred.com, which is operated on the Orchid commerce platform
- Email communications you receive from us
- Information you give us in person at our retail location, by phone, or by email
Your use of our website and your purchases from us are also governed by our Terms of Service, our Shipping Policy, and our Return Policy.
This policy does not cover the privacy practices of third parties whose sites we link to, or of platforms where we maintain a presence (such as Facebook, Instagram, or YouTube). Those services have their own policies and we do not control them.
Firearms transaction records are treated separately. Federal law governs what we must collect and how long we must keep it when you purchase or take transfer of a firearm. Section 4 explains this in detail, and it takes precedence over the general retention and choice provisions elsewhere in this policy.
2. Short Version
We collect what we need to sell you products, answer your questions, fulfill your orders, and — if you ask us to — send you email updates. We do not sell your personal information. Firearms transaction records required by federal law are kept separate from everything else, are never used for marketing, and cannot be deleted on request because federal law requires us to retain them.
The rest of this document is the detailed version.
3. Information We Collect
3.1 Information you provide to us
- Contact information — name, email address, mailing address, phone number
- Order and transaction information — items purchased, order history, shipping details, transferring or receiving FFL information
- Payment information — processed by our payment processor; see Section 7
- Class and event registration information — name, contact details, and any information required by an instructor for a training course
- Communications — the content of emails, contact-form submissions, and review or feedback submissions
- Marketing preferences — your email subscription status
3.2 Firearms transaction information
Collected only in connection with a firearm transfer, and governed by Section 4.
3.3 Information collected automatically
When you visit our websites we and our service providers may collect:
- IP address and approximate location derived from it
- Browser type and version, device type, and operating system
- Pages viewed, products viewed or searched for, referring URLs, and dates and times of access
- Cookie and similar identifiers
3.4 Cookies and similar technologies
We use cookies and similar technologies to keep the site working (for example, remembering the contents of a cart), to understand how the site is used, and to measure the performance of our advertising. Most browsers let you refuse or delete cookies through their settings. Some parts of our site may not work correctly if you block cookies.
We honor Global Privacy Control (GPC) browser signals as an opt-out of targeted advertising where we are able to detect them.
4. Firearms Transaction Records
This section describes information we collect and keep because federal law requires it. It is the most sensitive information we handle and we treat it accordingly.
4.1 What we collect
When you purchase or take transfer of a firearm from us, federal law requires you to complete ATF Form 4473, Firearms Transaction Record, and requires us to record the transaction. This includes your name, address, date of birth, place of birth, physical description, information from your government-issued photo identification, your responses to the eligibility questions on the form, the National Instant Criminal Background Check System (NICS) transaction number where applicable, and the make, model, type, caliber, and serial number of the firearm.
We also maintain an acquisition and disposition record (“bound book”) as required by federal regulation.
4.2 How long we keep it
We retain these records for the period required by federal firearms law. Under current federal regulation (27 C.F.R. § 478.129), licensees must retain each Form 4473 and each corresponding disposition record until the licensee discontinues business or licensed activity. If we discontinue our licensed activity, federal law requires that these records be delivered to the ATF. This retention period is set by regulation, not by us, and is subject to change if the regulation changes.
4.3 What we do with it
We use firearms transaction records only for federal and state firearms compliance. Specifically:
- We submit background check information to NICS or the applicable point-of-contact agency as required to complete a transfer
- We make these records available to the ATF for compliance inspections and in response to lawful firearms trace requests
- We disclose them to law enforcement where required by law, subpoena, or court order
- We report multiple handgun sales and firearm thefts or losses as federal regulation requires
We do not use firearms transaction records for marketing of any kind. We do not upload them, or any identifiers derived from them, to advertising platforms, analytics providers, data brokers, or lead-generation services. We do not sell or rent them. We do not use them to build advertising audiences.
Firearms transaction records are maintained separately from our marketing systems and our email list.
4.4 Limits on your choices regarding these records
Because federal law requires us to create and retain these records, you cannot ask us to delete, alter, or export them, and the choices described in Section 11 do not apply to them. This limitation applies only to the records described in this Section 4. Your contact preferences, marketing subscriptions, and non-firearms order history are handled under Section 11 as normal.
5. How We Use Information
We use the information described in Section 3 to:
- Sell and deliver the products and services you order, and to arrange transfers with other licensed dealers
- Process payments and prevent fraud
- Respond to your questions, requests, and appointment or consultation inquiries
- Register you for classes and notify you of scheduling changes
- Send transactional messages such as order confirmations, shipping notices, transfer-ready notifications, and appointment reminders
- Send marketing emails, where you have opted in
- Request reviews and feedback following a purchase
- Operate, secure, troubleshoot, and improve our websites
- Measure the effectiveness of our advertising
- Comply with our legal obligations, including firearms recordkeeping and reporting
6. Email Marketing
If you subscribe, we will send you periodic emails about new arrivals, events, classes, and shop news. Every marketing email includes an unsubscribe link, and we honor unsubscribe requests promptly. You will continue to receive transactional email related to orders and transfers regardless of your marketing subscription status.
7. Payments
Payment card information is submitted directly to our payment processor and is not stored on our servers. We retain only the limited transaction information needed for our records, such as the last four digits of the card, the authorization result, and the amount. Our processor’s handling of your payment information is governed by its own privacy policy and by applicable payment card industry standards.
8. Analytics and Advertising
We use third-party analytics and advertising services to understand how our websites are used and to measure our advertising. These services may set cookies or similar identifiers and may receive information about your visit, including pages viewed and actions taken.
The services we currently use are:
- Google Analytics 4, for website analytics
- Google Ads, for advertising measurement and conversion tracking
- Meta Pixel, for advertising measurement and conversion tracking
You can opt out of Google Analytics using the browser add-on Google provides, and you can adjust advertising preferences through the settings offered by Google and Meta. You may also use industry opt-out tools such as those offered by the Digital Advertising Alliance and the Network Advertising Initiative.
We do not provide firearms transaction information to any of these services. See Section 4.3.
We do not sell your personal information, and we do not share it with third parties for their own independent marketing purposes.
9. How We Share Information
We share personal information only in the following circumstances:
Service providers. We use vendors to run the business — including our commerce and firearms compliance platform, website hosting, payment processing, email marketing, shipping, and analytics. They may access personal information only to perform services for us, are bound by confidentiality obligations, and are not permitted to use it for their own purposes.
Legal and regulatory compliance. We disclose information where required by law, regulation, subpoena, court order, or lawful request from a government or law enforcement authority. For firearms transactions this includes the ATF and NICS as described in Section 4.
Protection of rights and safety. We may disclose information where we reasonably believe it is necessary to investigate or prevent fraud, security incidents, or illegal activity, or to protect the rights, property, or safety of Sutpen’s Hundred, our customers, or the public.
Business transfer. If we are involved in a merger, acquisition, or sale of assets, personal information may be transferred as part of that transaction. Firearms transaction records may only be transferred in a manner permitted by federal firearms law. We will provide notice before your information becomes subject to a different privacy policy.
We do not sell personal information.
10. Retention
We keep personal information only as long as we need it for the purposes described in this policy, or as long as the law requires:
| Category | Retention |
|---|---|
| Firearms transaction records (Form 4473, bound book) | As required by federal law — see Section 4.2 |
| Order and transaction records (non-firearms) | 7 years, for tax and accounting purposes |
| Marketing email list | Until you unsubscribe, plus a suppression record so we do not re-add you |
| Website analytics data | 14 months |
| Contact-form and inquiry records | 2 years |
11. Your Choices and Rights
Arizona does not currently have a comprehensive consumer privacy statute, and we have not represented that this policy grants rights under the European Union’s General Data Protection Regulation. Regardless, we offer the following to everyone:
- Access. Ask us what personal information we hold about you and we will tell you.
- Correction. Ask us to correct information that is wrong or out of date.
- Deletion. Ask us to delete your marketing and contact information. We will do so, subject to the limits in Section 4.4 and to records we must retain for tax, accounting, or legal reasons.
- Opt out of email. Use the unsubscribe link in any marketing email, or contact us.
- Opt out of targeted advertising. Use the tools described in Section 8, or send us a request.
To exercise any of these, contact us using the details in Section 14. We may need to verify your identity before acting, and we may decline requests that are unreasonably repetitive or manifestly unfounded.
If you are a resident of a state with a comprehensive consumer privacy law that applies to us, you may have additional rights under that law. Contact us and we will tell you what applies.
12. Security
We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These include encryption in transit, access controls limiting information to personnel who need it, and secure handling of firearms transaction records. No system is perfectly secure, and we cannot guarantee absolute security.
If we determine that a security breach affecting personal information has occurred, we will notify affected individuals as required by Arizona law, A.R.S. §§ 18-551 and 18-552 — within forty-five days after that determination — and will notify the Arizona Attorney General, the Director of the Arizona Department of Homeland Security, and the three largest nationwide consumer reporting agencies if the breach requires notification of more than 1,000 individuals.
13. Children and Age
Our websites and services are intended for adults. We do not knowingly collect personal information from children under 13. If we learn that we have collected such information, we will delete it. If you believe a child has provided us information, contact us at the details below.
Separately, federal and state law set minimum ages for the purchase and transfer of firearms and ammunition, and we verify age and eligibility as those laws require.
14. Contact Us
Sutpen’s Hundred, LLC
913b E. Indian School Rd
Phoenix, AZ 85014
Phone: (480) 866-8624, 9:00 AM to 4:00 PM Arizona Mountain Time
Email: troy@sutpenshundred.com
If you have questions about this policy, want to exercise a choice described in Section 11, or have a concern about how we handled your information, contact us and we will respond. If you are not satisfied with our response, you may contact the Arizona Attorney General’s Office.
15. Changes to This Policy
We may update this policy. When we do, we will revise the “Last Updated” date above and post the new version on our website. If we make material changes, we will provide additional notice — by email to subscribers, by a notice on our homepage, or both — before the change takes effect. Your continued use of our websites and services after a change takes effect means you accept the updated policy.
