Last Update: May 20th, 2019
If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.
The Information We Collect
- Registration Information: At the time you register for a newsletter, course 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 RS 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 RS 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 RS services. If you make sale and purchase transactions online through RS’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”).
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 RS 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 RS 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: RS will share your Payment Information with banks or vendors relevant to the transaction in order to enable transactions to be completed. In addition, RS may use Payment Information to determine your credit-worthiness and, in the process of such determination, RS may make such Payment Information available to banks or credit agencies. While RS 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. RS 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 credit-worthiness.
- 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 of 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 RS 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.
RS 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 RS, 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.
You can determine if and how a cookie will be accepted by configuring your browser, which is installed in the computer you are using to access the Site. If you desire, you can change those configurations in your browser. By setting your preferences in the browser, you can accept all cookies, you can be notified when a cookie is sent, or you can reject all cookies. If you reject all cookies by choosing the cookie-disabling function in your browser, you may be required to re-enter your information on our Site more often and certain features of our Site may be unavailable.
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 email@example.com.
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 RS 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 RS’s terms of service, or as otherwise required by law.
Security of your Personal Data
RS 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 firstname.lastname@example.org
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 RS, 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 RS.
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 Personal Data
Our Products are hosted and operated in the United States (“U.S.”) through RS and its service providers. We may transfer your Personal Data to the U.S., to any RS 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.
Accessing and Correcting Your Information
You can access, view and edit your Registration Information, Publishing Information and Payment Information (if any) through your Account with RS.
We reserve the right to make changes to this policy. Any changes to this policy will be posted.
If you reside in the EU, United Kingdom, Lichtenstein, Norway or Iceland, you can also contact our Data Protection Officer https://therossitersystem.com/official-statement-eu-gdpr-compliance/.