Rossiter Stretching LLC (“Rossiter Stretching”, “RS” , “Rossiter Stretching Technique”, “RST”, “Rossiter”, “Rossiter System”) Privacy Statement
Last Update: November 16th, 2020
RST is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Privacy applies to the RST site and governs data collection and usage. By using this Site, you consent to the data practices described in this Statement.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to email@example.com
YOUR EU GENERAL DATA PROTECTION REGULATION (GDPR) PRIVACY RIGHTS
Your principal rights under the EU General Data Protection Regulation (GDPR) are as follows:
- Right of Access: you have the right to be informed of, and request access to, the Personal Information we process about you.
- Right to Rectification: you have the right to request that we amend or update your personal data where it is inaccurate or incomplete.
- Right to Erasure: you have the right to have the Company delete your Personal Information.
- Right to Restrict: you have the right to request that we temporarily or permanently stop processing your Personal Information.
- Right to Object: you have the right to object to us processing your Personal Information on grounds relating to your particular situation or for direct marketing purposes.
- Right to Data Portability: you have the right to request a copy of your Personal Information in electronic format and the right to transmit that personal data for use in another party’s service.
- Right not to be Subject to Automated Decision Making: you have the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
THE INFORMATION WE COLLECT
- Registration Information: At the time you register for a newsletter, workshop or to become a Registered User of the Site, you will be asked to complete a registration form which requires you to provide information such as your name, address, phone/fax number, email address and other personal information as well as information about your business (“Registration Information.”)
- Publishing Information: If you submit any information to RST to be published on the Site through the publishing tools, then you are deemed to have given consent to the publication of such information so long as they do not pertain to personal information (“Publishing Information”).
- Buyer Information: we record and retain records of buying and browsing activities on our platform including but not limited to IP addresses, browsing patterns, buyer behavioral patterns, buyer contact details, buyer profiles and so forth (“Buyer Information”).
- Payment Information: If you establish a credit account with us or our providers or if you purchase a product or service from RST or other Registered Users of the Site or other vendors available through the Sites, we may collect additional information, including billing information, credit card numbers and expiration dates and tracking information from checks or money orders (“Payment Information”).
- Account Activities Information: We record and retain the records of your Account activities when you use the RST If you make sale and purchase transactions online through RST’s web-based transaction platform, we also collect information related to such transactions including the types and specifications of the goods, pricing and delivery information, any trade dispute records (“Account Activities Information”).
- Statistical Information: In addition, we gather statistical information about our Site and Users, such as IP addresses, browser software, operating system, software and hardware attributes, pages viewed, number of sessions, unique visitors and so forth (“Statistical Information”)
- Marketing Information: From time to time, we gather information about our Users and prospective users during trade shows, marketing events and other functions for follow up marketing purposes (“Marketing Information”).
- Personal Information: From time to time, our Users may disclose personal data deliberately or inadvertently including without limitation to personal identifiers such as name, email addresses, telephone number, facsimile number and IP address of individuals in the course of using the Site (“Personal Information”).
- Social Media Information: If a user links their social media profiles and accounts on this Site or other digital devices through social media networks (e.g., by clicking a Facebook “like” button), information may made available to, and collected by RST , through those social media profiles and accounts. In addition, if a user elects to connect their third-party devices or third-party applications (collectively “Third Party Apps”) to this Site or digital devices in order to utilize certain features and functionalities, we may collect information from such Third-Party Apps.
HOW WE MAY USE INFORMATION
- Registration Information: We may use your Registration Information to provide services that you request or to contact you regarding additional services about which RST determines that you might be interested. Specifically, we may use your email address, mailing address, phone number, mobile number, or fax number to contact you regarding notices, surveys, product alerts, new service or product offerings and communications relevant to your use of our Site. We may generate reports and analysis based on the Registration Information for internal analysis, monitoring and marketing decisions.
- Publishing Information: All of your Publishing Information will be publicly available on the Site and therefore accessible by any internet user. Any Publishing Information that you disclose to RST becomes public information and you relinquish any proprietary rights (including but not limited to the rights of confidentiality and copyrights) in such information. You should exercise caution when deciding to include personal or proprietary information in the Publishing Information that you submit to us.
- Payment Information: RST will share your Payment Information with banks or vendors relevant to the transaction in order to enable transactions to be completed. In addition, RST may use Payment Information to determine your creditworthiness and, in the process of such determination, RST may make such Payment Information available to banks or credit agencies. While RST has in place up-to-date technology and internal procedures to guard your Payment Information against intruders, there is no guarantee that such technology or procedure can eliminate all of the risks of theft, loss, or misuse. RST shall not be liable to you or any other person for any damages that might result from unauthorized use, publication, disclosure, or any other misuse of Payment Information, including credit card information.
- Account Activities Information: We use Account Activities Information to provide the services that you request. We may also generate reports, statistics and analysis based on Account Activities Information to enhance and improve our Site and services. We may also use Account Activities Information to determine your creditworthiness.
- Statistical Information: We use Statistical Information to help diagnose problems with and maintain our computer servers, to manage our Site, and to enhance our Site and services based on the usage pattern data we receive. We may generate reports and analysis based on the Statistical Information for internal analysis, monitoring and marketing decisions. We may provide Statistical Information to third parties, but when we do so, we do not provide personally identifying information without your permission.
- Buyer Information: We use Buyer Information to provide value-added services to our members including without limitation to providing buying pattern and buying behavioral data to our members to facilitate marketing initiatives and decision-making.
- Personal Information: We facilitate electronic commerce between businesses and our services should not be used by individual consumers or for personal use. Should Personal Information be disclosed for business purposes in the course of using our Site and services, such Personal Information may be used to provide value-added services to our members to facilitate including without limitation marketing initiatives and contacts. Uses of any Personal Information by any of our members are subject to privacy laws in the respective jurisdictions of our members. Each of our members is solely responsible for observing applicable laws and regulations in its respective jurisdictions to ensure that all use of the Site and Services are in compliance with the same. Each of our members is expressly prohibited from using any Personal Information for illegal activities including without limitation to spamming.
PROCESSING YOUR PERSONAL DATA
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your user agreement with us that allows us to provide you with the Products) and our “legitimate interests” or the legitimate interest of others (e.g. our users) such as:
- Personalizing, improving, or operating our Products and business
- Better understanding your needs and interests
- Fulfilling requests, you make related to the Products
- Providing you with information and offers from us or third parties
- Complying with our legal obligations, resolving disputes with users, enforcing our agreements
- Protecting, investigating, and deterring against fraudulent, harmful, unauthorized, or illegal activity
We process Personal Data for purposes such as:
- To process your orders and deliver the Products that you have ordered
- To provide reports based on information collected from use of our Products
- To keep you up to date on the latest Product announcements, software updates, software upgrades, system enhancements, special offers, and other information
- To provide support and assistance for our Products
- To provide the ability to create personal profile areas and view protected content
- To provide the ability to contact you and provide you with shipping and billing information
- To provide feedback and support
- To provide and administer opt-in contests, sweepstakes or other marketing or promotional activities on the Rossiter or affiliate websites
- To the extent you choose to participate, to conduct questionnaires and surveys in order to provide better products and services to our customers and end users
- To support recruitment inquiries
- To personalize marketing communications and website content based on your preferences, such as in response to your request for specific information on products and services that may be of interest
- To meet contract or legal obligations
You can choose whether to provide Personal Data to RST but note that you may be unable to access certain options, offers, and services if they require Personal Data that you have not provided. You can sign-up, and therefore consent, to receive email or newsletter communications from us. If you would like to discontinue receiving these communications, you can update your preferences by using the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this policy.
DATA SUBJECT RIGHTS
You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.
- Access:You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.
- Rectification:If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your member account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
- Objection:You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
- Erasure:You can request that we erase some or all of your Personal Data from our systems.
- Restriction of Processing:You can ask us to restrict further processing of your Personal Data.
- Portability:You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
- Withdrawal of Consent:If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Products.
- Right to File Complaint:You have the right to lodge a complaint about Rossiter’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
How long we retain your Personal Data depends on the type of data and the purpose for which we process the data.
RST and our third-party service providers automatically collect some information about you when you use our Products, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website and/or Products.
In addition, when you use some of our Products, network information is transmitted back to us such as Product usage information. This information is transmitted back to us so we can determine how users are interacting with our Products, to assist us with improving our Products, and to correct any problems that may occur.
DISCLOSURE OF INFORMATION
We may publish records of complaints and any penalties, actions, or proceedings against Members. We further reserve the right to disclose your Collected Information to relevant authorities where we have reason to believe that such disclosure is necessary to identify, contact or bring legal action against someone who may be infringing or threatening to infringe, or who may otherwise be causing injury to or interference with, the title, rights, interests or property of RST , our Users, customers, partners, other web site users or anyone else who could be harmed by such activities.
We also reserve the right to disclose Collected Information in response to a subpoena or other judicial order or when we reasonably believe that such disclosure is required by law, regulation, or administrative order of any court, governmental or regulatory authority.
If we have reason to believe that a User is in breach of the Terms & Conditions or any other agreement with us, then we reserve the right to make public or otherwise disclose such User’s Collected Information in order to pursue our claim or prevent further injury to RST or others.
What are cookies
- Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
- Cookies can be “persistent” or “session” cookies.
- When you use and access the Service, we may place a number of cookies files in your web browser.
- We use variations of both session and persistent cookies on the Site and Service and we use different types of cookies to assist in running the Service.
- Essential cookies. We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.
- Users who do not wish to have cookies placed on their computer should disable cookies through their web browser settings, with the understanding that disabling cookies may diminish a user’s experience on the Site and that certain features of the site may not function properly without the aid of cookies. Cookies are not harmful and cannot introduce viruses or extract personal information.
- In addition to our own cookies, we may also use various third-parties’ cookies to report usage statistics of the Service, deliver advertisements on and through the Site and Service, and so on.
What are your choices regarding cookies?
- Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
We partner with third parties to either display advertising on our website or to manage our advertising on other sites. Some of our third-party partners use technologies such as cookies and other technologies to gather information about your activities on this website, our affiliates’ websites, and unaffiliated websites in order to provide you advertising based upon your browsing activities and interests. With respect to our interest-based ads, we adhere to self-regulatory principles for online behavioral advertising issued by the Digital Advertising Alliance (“DAA”) and the European Interactive Digital Advertising Alliance (“EDAA”) (collectively, the “OBA Principles”). More information about the OBA Principles can be found at
https://digitaladvertisingalliance.org/principles and https://www.edaa.eu/european-principles/
If you wish to not have information about your online activities over time and across different websites used for the purpose of serving you interest-based ads, you can opt-out by clicking here and here (or if located in the EU click here). Please note that (1) this does not opt you out of being served ads, and even if you opt out of interest-based ads, you will continue to receive generic ads and (2) we store your opt-out preference for interest-based ads in a cookie on your device, and therefore you may have to opt out again if you delete your cookies.
When you download and use our Products, we automatically collect information on the type of device you use, operating system version, and the device identifier (or ”UDID“). We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you can turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
We collect information about where you are located when you are using our Products. We use this information for purposes such as optimizing your connection to our data center and suggesting customizations to your experience with our Products (e.g. your language preference). We share this information with parties such as our data center provider and our advertising partners. If you do not wish to allow us to share your information in this manner please opt-out by contacting us at firstname.lastname@example.org.
SHARING YOUR PERSONAL DATA
We do not sell or rent your Personal Data to third parties for marketing purposes unless you have granted us permission to do so.
We share personal data within RST and its affiliated companies, and with third party service providers for purposes of data processing or storage.
We also share Personal Data with business partners, service vendors and/or authorized third-party agents or contractors in order to provide requested Products or transactions, including processing orders, processing credit card transactions, hosting websites, hosting event and seminar registration and providing customer support. We provide these third parties with Personal to complete/utilize the requested Product or transaction.
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy. As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.
We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of RST’s Terms & Conditions, or as otherwise required by law.
SECURITY OF YOUR PERSONAL DATA
RST is committed to protecting the Personal Data you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. When we transfer credit card information over the Internet, we protect it using Secure Sockets Layer (SSL) encryption technology.
We recommend you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your Personal Data, you can contact us at email@example.com
LINKED WEBSITES AND THIRD-PARTY SERVICES
Our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this policy. We encourage you to review the privacy policies posted on these (and all) sites you visit or services you use.
If you participate in a discussion forum or Support chat , you should be aware that the information you provide there will be made broadly available to others, potentially inside or outside RST, who have access to that discussion forum or Support chat. Also, please recognize that individual forums and chat rooms may have additional rules and conditions. Each participant’s opinion on a forum or chat room is his or her own and should not be considered as reflecting the opinion of RST.
RST does not knowingly collect Personal Information from any child under the age of 13.
We employ commercially reasonable security methods to prevent unauthorized access, maintain data accuracy and ensure correct use of information.
As a Registered User, your Registration Information, Publishing Information and Payment Information (if any) can be viewed and edited through your Account, which is protected by a Password. We recommend that you do not divulge your Password to anyone. Our personnel will never ask you for your Password in an unsolicited phone call or in an unsolicited e-mail. If you share a computer with others, you should not choose to save your login information (e.g., User ID and Password) on the computer. Remember to sign out of your Account and close your browser window when you have finished your session.
No data transmission over the Internet or any wireless network can be guaranteed to be perfectly secured. As a result, while we try to protect your information, no web site or company, including ourselves, can absolutely ensure or guarantee the security of any information you transmit to us and you do so at your own risk.
TRANSFER AND STORAGE OF YOUR PERSONAL DATA
Our Products are hosted and operated in the United States (“U.S.”) through RST and its service providers. We may transfer your Personal Data to the U.S., to any RST affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage. By using any of our Products or providing any Personal Data for any of the purposes stated above, you consent to the transfer and storage of your Personal Data, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers.
SO-NOT-TRACK POLICY AND PROCEDURES
RST does not currently respond to “do not track” browser headers or specific “do not track” requests. You do have the ability to limit tracking through these third-party programs and by taking the actions listed below. The use of online tracking mechanisms by third parties is governed by those third-parties’ own privacy policies, and not the terms included hereunder. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may adjust the settings of your own web browser to block the placement of cookies. You may remove yourself from the targeted advertising of companies by contacting the Network Advertising Initiative, or of companies participating in the Digital Advertising Alliance program by contacting them directly.
INTERNATIONAL PRIVACY PRACTICES
RST is primarily operated and managed on servers located and operated within the United States. In order to provide Services to you, RST may send and store your Personal Information outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your Personal Information may be transferred outside of the country where you reside or are located, including countries that may not or do not provide the same level of protection for your Personal Information. RST is committed to protecting the privacy and confidentiality of Personal Information when it is transferred. If you reside or are located within the European Economic Area and such transfers occur, RST takes appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the European Economic Area to the extent feasible under applicable law. By using and accessing our Services, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of Personal Information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.
ACCESSING AND CORRECTING YOUR INFORMATION
As a registered user you can access, view, and edit your Registration Information, Publishing Information and Payment Information (if any) through your account with RST.
We reserve the right to make changes to this policy. Any changes to this policy will be posted.
Any questions, clarifications, changes to personal information or opt out needs, or any other concerns regarding this Privacy Statement, please contact Rossiter Stretching LLC at firstname.lastname@example.org