2. The Information We Collect
When you use our Services, we collect and receive information in various ways. We collect information provided by you, usage information, and information about your devices. Here is an overview of the types of information we collect about you:
2.1. Information You Provide Us
We receive the information that you provide us when filling out online forms or engaging with us, such as when setting up your account, making a purchase, or communicating with us. In addition, if you connect a social network you belong to (such as Facebook) to your RPL account, you authorize these social networks to share your information with us.
2.2. Information We Collect When You Are on RPL Platforms
Usage Information – Examples include your interactions, shopping preferences and your interaction with our Website and advertisements. Collecting this information allows us to make your RPL experience more personalized such as by recommending products that you might like and offering you promotions in which you might be interested. It also makes the navigation of the site more seamless and faster.
Technology Information – As with all websites and applications, there is a web protocol that sends us information about how you are accessing our Services, such as your device type (mobile versus desktop), IP address, operating system, and what settings you have enabled. Your device, browser, and software settings affect what information your device or browser makes available to us, and how we will deliver the Services to you.
Cookies, Analytics, and Third Party Technologies – We collect information through the use of “cookies”, tracking pixels, data analytics tools like Google Analytics, SDKs, and other third party technologies to understand how you navigate through the Services and interact with RPL advertisements, to make your RPL experience secure, to learn what content is popular, to improve your site experience, to serve you better ads on other sites, and to save your preferences. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the Services. Your web browser(s) has settings to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may not be able to access certain features of our Services, such as our ability to recommend products and services based on our search history. However, you will still be able to perform necessary functions such as ordering and shopping.
2.3. Information from Service Providers and Vendors
Third party services provide us with information needed for core functions of our Services, as well as for additional programs and promotions that can enhance your RPL experience. These third-party services include payment processors, fraud monitoring, marketing service providers, and other businesses or publicly available sources. We obtain the following information about you from these third-party services:
- Information, such as your IP address, interactions with our website and payment processing, to make RPL Services more secure, like fraud detection
- Information about your participation in third party programs that provide things such as payment, transaction, and fraud detection information (i.e. Braintree, Paypal)
Information, such as your social media profile (such as Facebook and Instagram), about you provided by specific services, such as demographic and market segment information
3. How We Use your Information
We may use the Personal Information we collect for one or more of the following purposes:
- To assist you with your use of the Services. For example, if you ask a question about any of the products we carry, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product, we will use the Personal Information you provide to process your order and facilitate delivery.
- To provide, support, personalize, and develop our Services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, payments and prevent transactional fraud. We may also save your Personal Information to facilitate new products orders or process returns.
- To personalize your experience using the Services and to deliver product offerings relevant to your interests, including targeted offers and ads through our Services, third-party sites, and via email (with your consent, where required by law).
- For testing, research, analysis, and product development, including to develop and improve our Services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations, including responding to a court order, summons, warrants. Also to exercise or defend legal claims, protect against harm to our rights, property, interest or safety of the rights, property, interests or safety of you, third-parties, or the public as required or permitted by the law.
4. How & With Whom We Share Information
We may share your Personal Information with third parties, such as service providers and vendors, for certain legally permissible reasons to provide you with a features and options related to our Services.
4.1. Sharing Information With Third-Party Service Providers for Business Purpose
RPL may share the following categories of your Personal Information for a business purpose:
- Identifiers – Examples include your name, postal address, email address and IP address. We collect and store this information in order to verify your identity and prevent against fraudulent transactions. We also collect and store this information to enable purchases, delivery and customer service in connection with your membership.
- Commercial Information – Examples include your purchase history and types of products purchased or viewed. We collect and store this information to protect against fraud by ensuring that we have accurate and verified history of your legitimate purchases. We also collect this information in order to make your membership experience more personalized. It allows us to recommend products that you might like and offer you promotions in which you might be interested.
- Internet or similar network activity – Examples include your shopping preferences and your interaction with our website and advertisements. We collect and store this information in order to make your membership experience more personalized. It allows us to recommend products that you might like and offer you promotions in which you might be interested. It also makes the navigation of the site more seamless and faster.
We disclose those categories of Personal Information to service providers to fulfill the following business purposes:
- Maintaining and servicing your account;
- Processing or fulfilling orders;
- Providing you customer service;
- Verifying the identity of users;
- Detecting and preventing fraud;
- Providing promotional programs;
- Providing marketing and advertising services to RPL
- Providing analytics services to RPL; and
- Undertaking internal research to develop the RPL Services.
4.2. Information that’s no longer personally identifiable.
We may create aggregated and other anonymous data from your Personal Information and other individuals whose Personal Information we collect. We make Personal Information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
4.3. Legal & Safety Reasons
4.4. In Connection with a Sale, Merger Acquisition
5. Storing & Protecting Your Information
We retain Personal Information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax or accounting requirements; to establish or defend legal claims; or for fraud prevention). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We endeavor to protect the privacy of your account and other Personal Information we hold in our records. We take certain measures designed to protect your Personal Information, such as conducting risk assessments and use readily available security measures to periodically monitor systems and assets to identify data security events, imposed reasonable data access controls, and have a process to secure and inventory devices with access to Personal Information. Unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
6. Other Third-Party Websites
Our Services, particularly our website, app and promotional emails may contain links to third-party websites and services. For example, if you are looking at a product, we may have a link to the manufacturer’s website or when you may sign-in to our website using your Facebook account and Facebook is governed by own policies. Linked third-party websites and services may have privacy policies that differ from ours. We are not responsible for those websites, and we recommend that you review their policies. Please contact those websites directly if you have any questions about their privacy policies.
7. Your Rights and Choices Regarding Your Data
7.1. All Users
Email Subscriptions. You can always unsubscribe from our commercial or promotional emails by clicking unsubscribe in those messages. We will still send you transactional and relational emails about your use of our Services. Account Information. You can review and edit certain account information you have chosen to add to your profile by logging in to your account settings and profile. Cookie Tracking. You can modify your cookie settings on your browser, but if you delete or choose not to accept our cookies, you may be missing out on certain features of our Services, such as certain product recommendations features. However, you will still be able to order and complete a transaction on our website. Do Not Track. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. Our Services may not support Do Not Track requests. Deleting Your Account. You may request termination of your account or deletion of certain information by emailing firstname.lastname@example.org. In some cases, we will be unable to delete your account, such as if there is an issue with your account related to trust, safety, or fraud or due to our legal obligation to notify you about the recall of a product you purchased. When we delete your account, we may retain certain information for legitimate business purposes or to comply with legal or regulatory obligations. For example, we may retain your information to notify you about the recall of a product you purchased. When we retain such data, we do so in ways designed to prevent its use for other purposes. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
7.2. California Residents
California has passed a new law called the California Consumer Privacy Act (CCPA). The contours of the law are still being sorted out and we are making our best attempt at interpreting it as of the date of this policy. If the CCPA is applicable to you, you have the right to:
- Know the categories of Personal Information collected about you and its sources and business purpose;
- Know whether your Personal Information is sold or disclosed, and to whom;
- Opt out of the sale of your Personal Information;
- Access and then delete your Personal Information; and
- Equal service and price (non-discrimination) if you exercise your privacy rights.
“Personal Information” is defined to include information that identifies, relates to, describes, or is capable of being associated with a particular consumer or household. This includes (among other types of Personal Information) IP addresses, geolocation data, biometric information, and “unique identifiers” such as device and cookie IDs, Internet activity information like browsing history, commercial information such as products or services purchased or consuming histories or tendencies, and characteristics concerning an individual’s race, color, sex (including pregnancy, childbirth, and related medical conditions), age (40 or older), religion, genetic information, sexual orientation, political affiliation, national origin, disability or citizenship status. Inferences drawn from Personal Information “to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes” are also considered “Personal Information.”
Exercising Your Rights under the CCPA & Account Verification Process
To exercise your rights described above, please submit a request to us by:
Sending an email to email@example.com.
Please include the following information in your request, as part of the CCPA account verification process:
- Subject Line: CCPA Data Subject Request
- Name associated with your RPL account
- Email address associated with your RPL account
- State of residence
- Billing zip code
- Your most recent RPL Order Number (if applicable)
If you are an authorized agent acting on behalf of the requestor, please include written proof that you are an authorized agent such as a signed power of attorney.
*Failure to provide any of the above items may cause a delay in responding to your request.
Limitation on the Requests
The rights under the CCPA are evolving and additionally are not absolute, as they are subject to certain exceptions or limitations, thus we may be required or permitted by law to decline your requests. Only you, a person you authorize to act on your behalf or an entity registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable requests related to accessing or deleting your Personal Information.
Some Other Things to Note when Exercising your Rights under the CCPA
You may only make a request for access or data portability twice within a 12-month period.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We will respond to your request within forty-five (45) days of receipt. If we require more time (up to 45/90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically to the email address provided. Any disclosures we provide will only cover the 12-month period preceding the request’s receipt. If applicable, the response we provide will also explain the reasons we cannot comply with a request. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
7.3 Nevada Residents
Under Nevada law, Nevada residents may have certain rights including to review and request changes to your information. You may review and request changes to your information by visiting your account settings on our Sites or platforms. For any questions related to your rights, please contact firstname.lastname@example.org.
8. Children’s Data
10. What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to email@example.com, and we will try to resolve your concerns.
Last Updated: May 2021