• You have certain rights regarding the Personal Data we collect from you, which you can learn about below.
• The services are hosted and operated in the United Kingdom through Rats to Riches Inc. By using our services, you acknowledge that any Personal Data you provide to us will be hosted on United Kingdom servers. Rats to Riches, Inc. is located at the Greenheys Business Centre, 61 Pencroft Way, Manchester, M15 6JJ.
PERSONAL DATA YOU PROVIDE US
We collect your name, email address and physical address when you register for the BETA version of Rats to Riches or when you purchase any products listed on the website.
We also use your email address:
• to send you information and materials about us, our products and our services that we think may be of interest to you, based on our legitimate business interest in marketing to individuals who have indicated an interest in our products and services. You can decide to stop receiving this information at any time by emailing us at firstname.lastname@example.org or reach out to us on any social media platforms.
SHIPPING AND PAYMENT INFORMATION
When you order products through the website, we collect your first and last name and your shipping address (collectively, "Shipping Information"), as well as certain payment information, including your billing address and your credit or debit card type, number, security code and expiration date (collectively, "Payment Information"), and we use this information in order to process, fulfill, confirm, or notify or inform you about your purchase orders, Without this information, we would be unable to complete your transaction with us and/or deliver your purchases to you.
You can always have us delete your Shipping Information at any time by emailing us at email@example.com or reach out to us on any social media platforms.
OTHER PERSONAL DATA WE RECEIVE ABOUT YOU
In addition to the information you directly provide us, we automatically receive and record certain information about you when you access or use the Rats to Riches website, such as your customer trip and experience on our website (what pages you have accessed and time spent on each page).
• enable you to access and use our website and other features that you request or seek to use, based on our legitimate business interest in providing you with our services. For example, certain Cookies enable you to use the "shopping cart" functionality on the website. Such Cookies are generally known as "essential cookies." You can disable these Cookies, but doing so will encumber the performance of the website and may make certain of its features and services unavailable to you;
• understand how visitors use the Services, such as by collecting information about the number of visitors to our website, what pages visitors view on our website and how long visitors are viewing pages on the website, based on our legitimate business interest in improving and maintaining the accessibility and functionality of our Services. Such Cookies are generally known as "performance/analytical cookies," and are persistent Cookies. Through these Cookies, we may collect information about your online activity after you leave our Services.
You can decide whether or not to accept most Cookies. Most browsers allow you to delete Cookies and have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allowing you to decide whether to accept each new Cookie in a variety of ways. To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu. You can always choose to stop us from collecting your Cookie Information by turning off the Cookie feature on your browser or by ceasing to use the Services. However, if you do prevent us from collecting your Cookie Information, you should know that some of the Services may not work properly.
If you'd like to know more about Cookies, including information about how to manage, disable and delete them, you can visit http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm, https://ico.org.uk/for-the-public/online/cookies/, http://www.youronlinechoices.com/uk/or http://www.allaboutcookies.org/.
INFORMATION FROM ADVERTISING AND ANALYTICS PARTNERS
We work with advertising and analytics companies that provide us with certain information about you, your interactions with us and your usage on the website. Cookie Information, hashed email addresses, unique identifiers assigned to you by our Advertising Partners, as well as pages or content you've viewed, links you've clicked or other actions you've taken on our website. We use this information in order to enhance our understanding of your interests and preferences, so that we can serve you with Interest-Based Ads and measure their effectiveness, based on our legitimate business interest in marketing to individuals who we think may be interested in our services and products. We sometimes attempt to direct Interest-Based Ads to individuals who fit a certain general category, and as a result of the information our advertising and analytics partners provide us, Interest-Based Ads or other advertisements or recommendations may appear on Third Party Services that you visit.
To collect the information described above, as well as to serve targeted advertisements to you, our advertising and analytics partners sometimes integrate their own Cookies, including web beacons, into the Services and/or into Third Party Services that you visit, as mentioned above. Remember, you can elect not to have these Cookies collect your information on the Services. Also, your browser or device may offer you a "Do Not Track" or "DNT" option, which allows you to signal to operators of Third Party Services (including, without limitation, behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites; however, we cannot and do not make any promises about how such Third Party Services will react when you set this signal on your browser.
You may also consider changing your settings to block third party Cookies generally, where possible. Again, if you'd like to know more about Cookies, including information about how to manage, disable and delete them, you can visit http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm, https://ico.org.uk/for-the-public/online/cookies/, http://www.youronlinechoices.com/uk/ or http://www.allaboutcookies.org/.
We sometimes request and receive information about your transaction history from our Payment Processor in order to process your purchase orders, or to enroll you in discount, rebate and other programs in which you have elected to participate and use it to verify your identity by combining it with information you provide us, based on our legitimate business interest in protecting against fraudulent transactions.
WHO WE SHARE YOUR PERSONAL DATA WITH
We share your Personal Data within our company. We also share your Personal Data with third party vendors, service providers and agents, for the purposes and on the legal bases discussed herein, including: with shipping and logistics companies, our Payment Processor and others that we rely on to provide you with the products or process and fulfil your purchase orders.
If you post information or content publicly on or through the Services (including when you submit comments or reviews of our shave plans, products or Services), or post content publicly elsewhere, including on your social media accounts, that relates to us or the Services, we may receive and share that public information with third parties, based on our legitimate business interest in marketing our products and services.
CHANGE OF OWNERSHIP OR CONTROL
LAWS AND SAFETY
We also reserve the right to access, read, preserve and disclose your Personal Data as we reasonably believe is necessary to:
• satisfy any applicable law, regulation, legal process or governmental request;
• protect our rights, property or safety, and those of our users, customers and the public.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA AND PRIVACY SHIELD
We sometimes transfer your Personal Data outside of the European Union, Iceland, Norway or Lichtenstein to our authorized third party agents, vendors and service providers. When we do so, it is our practice to use contracts with standard provisions approved by the European Commission that give Personal Data the same protection it has in Europe, or, where we use third party agents, vendors and service providers based in the United States, we may transfer data to them if they are part of the Privacy Shield (more on this below), which requires them to provide similar protection to Personal Data shared between Europe and the United States.
WHAT YOUR RIGHTS ARE TO YOUR PERSONAL DATA, AND HOW YOU CAN EXERCISE THEM
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request with respect to these rights, you can email firstname.lastname@example.org. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous, inaccurate or extremely impractical, if it jeopardizes the rights of others or if it is not required by law, but in those circumstances we will still respond to notify you of such a decision. In some cases, we may need you to provide us with additional information, which may include Personal Data, as necessary to verify your identity and the nature of your request.
RIGHT OF ACCESS
• Where permissible, you can request more information about the Personal Data we hold about you and you can request a copy of your Personal Data.
RIGHT OF 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 Personal Data.
RIGHT OF ERASURE
• Where permissible, you can request that we erase some or all of your Personal Data from our systems. You can also delete your account with us at any time by emailing us at email@example.com
RIGHT TO WITHDRAW 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 to this processing at any time, which you can do by emailing us at firstname.lastname@example.org. 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 Services.
RIGHT TO OBJECT TO PROCESSING AND TO RESTRICT PROCESSING
• Where permissible, you can let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as marketing to you (to name one example), and you can also ask us to restrict further processing of your Personal Data.
RIGHT OF PORTABILITY
• Where permissible, you can ask for a copy of your Personal Data in a machine-readable format, and you can also request that we transmit the data to another controller where technically feasible.
RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
• You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. Please visit http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm for more information.
OUR PERSONAL DATA RETENTION POLICY
We retain your Personal Data for longer, if doing so is necessary to pursue our legitimate business interests (but only if those interests are not overridden by your own interests, rights and freedoms), comply with our legal obligations, resolve disputes or collect fees owed, conduct audits, or if doing so is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we dispose of your Personal Data securely, but may retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
As stated above, you can request us to erase some or all of your Personal Data from our systems, and you can delete your account with us at any time, by emailing us at email@example.com
ANY QUESTIONS OR CONCERNS?
If you have any questions or concerns regarding how we collect, use, protect or share your Personal Data, including, for example, about our legitimate business interests or the legitimate business interests of others that we describe above, please send a detailed message to firstname.lastname@example.org.
25 May 2018