1. Important information and who we are
Purpose of this privacy noticeThis privacy notice aims to give you information on how Robertson Marketing Group, Inc. and its subsidiaries (collectively referred to as “Robertson Marketing” or "we", "us" or "our") we collect and process your personal data through your use of our site, including any data you may provide through our site when you sign up to our newsletter, purchase a product or register an account with us. Our site is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller and processorRobertson Marketing is considered a controller and processor under the European Union General Data Protection Regulation (“GDPR”) and responsible for your personal data. We are made up of different legal entities including Robertson Marketing Group, Inc. incorporated in the United States and Robertson Marketing Group United Kingdom Limited incorporated and registered in England. When we mention Robertson Marketing or "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Robertson Marketing Group, Inc. organization responsible for processing your data. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact detailsOur full details are: Full name of legal entity: Robertson Marketing Group, Inc. Email address: firstname.lastname@example.org Postal address: 359 Kessler Mill Rd, Salem, Virginia 24153 U.S.A.
Should you have any concerns, we would appreciate the chance to deal with them directly. If you would like to speak to us regarding any concerns you have, please contact us by email at email@example.com.
If you are a citizen of a European Union country, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the United Kingdom supervisory authority for data protection issues (www.ico.org.uk).
If you are a citizen of the United States you have the right to make a complaint at any time to the attorney general office in your home state.
Third-party linksThis website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data that you give us through our site or by using our applications, corresponding with us by phone, e-mail or otherwise about you which we have grouped together as follows:
• Identity Data includes first name, middle name, maiden name, last name, username or similar identifier.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you.
• Usage Data includes information about how you use our site and products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us or our third parties and your communication preferences. Please keep us informed if your personal data changes during your relationship with us. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal dataWhere we need to collect personal data by law, or under the terms of a contract you intend to make with us and you fail to provide that data when requested, we may not be able to perform the contract (for example, to provide you with goods). In this case, we may be unable to process an order for a product or we may have to cancel a product you have ordered with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
Direct interactions. You may give us, your Identity, Contact Data, and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: • Place an order for our products;
• Create an account on our website;
• Subscribe to our newsletters;
• Request marketing to be sent to you; or
• Give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
• Technical Data from the following parties: analytics providers such as Google based outside the EU; and
• Contact Data, Financial Data, and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU, or your employer or customer.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to comply with a legal or regulatory obligation, including from law enforcement; or
• To the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal dataWe have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate (please see paragraph 10 (Glossary) for a definition of legitimate interest). Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you (please see paragraph 10 (Glossary) for a definition of performance of a contract)|
|To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation (please see paragraph 10 (Glossary) for a definition of comply with a legal or regulatory obligation)|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile||Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing.
Promotional offers from usWe may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing). You will receive marketing from us if you have requested information from us or purchased goods from us and, in each case, you have not opted out of receiving that marketing.
Third-party marketingWe will get your express opt-in consent before we share your personal data with any company outside Robertson Marketing of companies for marketing purposes.
Opting outYou can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving marketing, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience or other transactions.
About cookiesA cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. Cookies can be used by web servers to identity and track users as they navigate different pages on a website and identify users returning to a website.
List of Google Cookies:
|g_enabled_idps||Used for Google Single Sign On|
|_utma, _utmb, _utmc, _utmt and utmz , _ga , _gid||Google Analytics cookies|
|_dc_gtm||Google Tag Manager|
Blocking cookies:Most browsers allow you to refuse to accept cookies; for example:
• In Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
• In Firefox (version 24) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites";
• In Chrome (version 29), you can block all cookies by accessing the "Customize and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading. Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website
Deleting cookies:You can delete cookies already stored on your computer; for example:
• In Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835);
• In Firefox (version 24), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history", clicking "Show Cookies", and then clicking "Remove All Cookies";
• In Chrome (version 29), you can delete all cookies by accessing the "Customize and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Delete cookies and other site and plug-in data" before clicking "Clear browsing data". Deleting cookies will have a negative impact on the usability of many websites.
List of Cookies Managed by Our Website
|Cookie Name||Cookie Description|
|jsessionid||Session cookie identifies the session and does not store or retrieve any personal user information. This cookie expires when the session is closed.|
|anon||Anonymous cookie is used as a user identifier when you are not yet logged in on the site.|
|_navigation||This cookie keeps track of the pages visited on the site.|
|theme||Used for storing the theme/skin currently used on site.|
|xacacheid, xscacheid, xucacheid||Used for server side caching of store pages.|
Change of purposeWe will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal dataWe may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. Internal third parties such as our employees or officers and legal entities within Robertson Marketing. External third parties including specialist IT support, suppliers and sub-contractors for the performance of this site, our applications and any contract we enter into with them or you including CCH, Avalara, delivery companies to deliver your order (such as UPS, Fedex, DHL, Royal Mail, Interlink), payment solutions, PayPal, CyberSource, Authorize.Net, and others such as Ariba and Coupa. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfersWe share your personal data with other members of Robertson Marketing and between countries in which we operate. This will involve transferring your data outside your home country, some countries to which we may transfer your personal data outside of the EEA do not have an adequate level of protection for personal data approved by the European Commission. However, where we use certain service providers (as per paragraph 5), we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA
7. Data securityWe have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retentionHow long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If you have registered to receive communications from us as part of our mailing list, then we will keep your personal data for up to 7 years, at which time we will seek to obtain consent from you to continue storing your data and contacting you.
9. Your legal rightsUnder certain circumstances, you have rights under data protection laws in relation to your personal data.
MarketingWe will inform you (before collecting your data) if we intend to use your data for marketing purposes. We will only use your data for this if you have not opted out.
Correction of informationIf you notify us that the personal data we hold is complete or inaccurate we will correct or complete the information as soon as possible.
Deletion of informationYou have the right to request that your personal data be deleted; including if we no longer need it for the purpose we collected it, or, where our legal basis for processing is that you have given consent, you withdraw your consent. Following such a request we will erase your personal data without undue delay unless continued retention is necessary and permitted by law. If we made the personal data public, we will take reasonable steps to inform other data controllers processing about your erasure request.
Object to processingYou have the right to object to us processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Restriction on processingYou have the right to request that we suspend processing your personal data, but hold it for you, in the event the personal data we hold is inaccurate, the processing is unlawful or we no longer need the personal data. Once the processing is restricted, we will only continue to process your personal data if you consent or we have another legal basis for doing so.
Access to informationYou have the right to access information held about you and any access request will usually be free of charge. We will endeavor to provide information in a format requested, but we may charge you a reasonable fee for additional (duplicate) copies.
Data PortabilityYou have the right to receive a copy of your personal data which you gave to us. The copy will be provided in a commonly used and machine-readable format. You can also have it transmitted directly from us to another data controller, where reasonably technically possible. If you wish to exercise any of the rights set out above, please Contact us.
No fee usually requiredYou will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Withdraw consent at any timeYou may withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
What we may need from youWe may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respondWe try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
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