USE BY MINORS
The Service is not directed to individuals under the age of 18, and we request that these individuals not provide personal information through the Service. If your child has submitted Personal Information and you would like to request that such Personal Information be removed, please contact us as explained below under CONTACTING US.
We may ask you to submit personal information and/or financial information in order for you set up an online user account (an “Account”), to benefit from certain features (such as newsletter subscriptions, tips/pointers, or order processing) or to participate in a particular activity (such as sweepstakes or other promotions). You will be informed what information is required and what information is optional.
We may combine the information you submit with other information we have collected from you, whether on or offline, including, for example, your purchase history. We may also combine it with information we receive about you from other sources, such as our affiliates, publicly available information sources (including information from your publicly available social media profiles), and other third-party information providers.
Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, health, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the Service or otherwise to us.
AUTOMATIC INFORMATION COLLECTION AND USE
We and our service providers may automatically collect and use information in the following ways as you navigate around the Service:
- Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access the Service through a mobile device. We use this information to ensure that the Service functions properly.
- You can refuse to accept these cookies by following your browser's instructions; however, if you do not accept them, you may experience some inconvenience in your use of the Service. You may also not receive advertising or other offers from us that are relevant to your interests and needs. To learn more about cookies, please visit http://www.allaboutcookies.org.
- Using Flash cookies: Our use of Adobe Flash technology (including Flash Local Stored Objects ("Flash LSOs")) allows us to, among other things, serve you with more tailored information, facilitate your ongoing access to and use of the Service, and collect and store information about your use of the Service. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
- Using pixel tags, web beacons, clear GIFs, or other similar technologies: These may be used in connection with some Service pages and HTML formatted e mail messages to, among other things, track the actions of users and e mail recipients, measure the success of our marketing campaigns, and compile statistics about Service usage.
- IP address: Your IP address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP address is identified and logged automatically in our server log files whenever a user visits the Service, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many online services. We use IP addresses for purposes such as calculating Service usage levels, diagnosing server problems, and administering the Service. We may also derive your approximate location from your IP address.
- Device Information: We may collect information about your mobile device, such as a unique device identifier, to understand how you use the Service.
HOW WE USE AND DISCLOSE INFORMATION
We use and disclose information you provide to us as described to you at the point of collection. Please see the section entitled "Choices and Access," below, to learn how you may opt out of certain of our uses and disclosures.
Where required by applicable law, we will obtain your consent to our use of your personal information at the point of information collection. We may also use information from or about you as necessary to perform a contract, to comply with a legal obligation (for example, due to our pharmacovigilance obligations), or for our legitimate business interests. We may also rely on other legal bases, specifically for:
- Providing the functionality of the Service and fulfilling your requests.
- to provide the functionality of the Service to you and providing you with related customer service;
- to create Accounts to utilize the Services;
- to respond to your inquiries and fulfill your requests, such as to send you documents you request or e mail alerts;
- to send you important information regarding our relationship with you or regarding the Service, changes to our terms, conditions, and policies and/or other administrative information.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Accomplishing our business purposes.
- for data analysis, for example, to improve the efficiency of the Service;
- for processing sales transactions;
- for audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
- for fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- for developing new products and services;
- for enhancing, improving or modifying our website or products and services;
- for identifying Service usage trends, for example, understanding which parts of our Service are of most interest to users; and
- for determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
- Analysis of Personal Information to provide personalized services.
- to better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests;
- to better understand your preferences so that we can deliver content via the Service that we believe will be relevant and interesting to you.
We will provide personalized services either with your consent or because we have a legitimate interest.
We also disclose information collected through the Service:
- to our third party partners with whom we offer a co branded or co marketed promotion;
- to our third party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, e mail and direct mail delivery services, auditing, and other services, in order to enable them to provide services; and
- as permitted by applicable law, to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
In addition, we may use and disclose your information as we believe to be necessary or appropriate: (a) to comply with legal process or applicable law, which may include laws outside your country of residence; (b) as permitted by applicable law to respond to requests from public and government authorities, which may include authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others. We may also use and disclose your information in other ways, after obtaining your consent to do so.
We may use and disclose information we collect automatically as described above, under "Automatic Information Collection and Use." In addition, where allowed by applicable law, we may use and disclose information that is not in personally identifiable form for any purpose. If we combine information that is not in personally identifiable form with information that is identifiable (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your personal information
We give you choices regarding our use and disclosure of your personal information for marketing purposes. You may opt out from:
- Receiving marketing communications from us: If you no longer want to receive marketing communications from us on a going forward basis, you may opt out of receiving them by contacting us as described in the CONTACTING US section. In your request to us, please provide your name, identify the form(s) of marketing communications that you no longer wish to receive, and include the address(es) to which it/they are sent. For example, if you no longer wish to receive marketing e mails or direct mail from us, tell us that, and provide your name and e mail or postal address. If available, you may also opt out of receiving marketing communications from us by visiting the Service to update your online profile. In addition, you may opt out of receiving marketing e mails from us by following the unsubscribe instructions provided in any such message.
- Our sharing of your personal information with affiliates and third party partners: If you previously opted in to receiving marketing communications from our affiliates or third party partners, you may opt out of our sharing of your personal information with those parties for their direct marketing purposes on a going forward basis by contacting us as described in the CONTACTING US section. In your communication to us, please state that we should no longer share your personal information with our affiliates and/or third party partners for their marketing purposes, and include your name and e mail address.
We will seek to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out as described above, we will not be able to remove your personal information from the databases of our affiliates with which we have already shared your information (i.e., as of the date that we implement your opt out request). Please also note that if you opt out of receiving marketing related messages from us, we may still send you important transactional and administrative messages, from which you cannot opt out.
How you can access, change, or delete your personal information
Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Service or by providing consent to us (where required by law), your information may be transferred to countries outside of your country of residence which may provide for different data protection rules than in your country. Appropriate contractual and other measures are in place to protect personal information when it is transferred to our affiliates or third parties in other countries.
We seek to use reasonable organizational, technical, and administrative measures designed to protect personal information under our control. Any payment transactions will be encrypted using SSL technology. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us in accordance with the "CONTACTING US" section below.
We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Service to you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
THIRD PARTY SITES AND SERVICES
CCPA RAKUTEN DISCLOSURE
- The below companies may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links.
YOUR PRIVACY RIGHTS AND INTERNATIONAL PRIVACY PRACTICES
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy.
If you are a Canada resident, Canadian law may provide you with additional rights regarding our use of your personal information. To learn more about your Canada privacy rights, visit https://www.priv.gc.ca/en/.
If you are a resident of the European Union/European Economic Area (the “EU”), the General Data Protection Regulation 2016/679 and EU Directive 95/46/EC (collectively, the “GDPR”) may provide you with additional rights regarding our use of your personal information. To learn more about your GDPR privacy rights, visit https://eugdpr.org/the-regulation/.
Controls and choices
Certain users (such as users in the EU) have certain legal rights to obtain confirmation of whether RoC holds personal data about them, to access personal data RoC holds about them (including, in some cases, in portable form), and to obtain its correction, update, amendment or deletion in appropriate circumstances. Those users may also object to RoC’s uses or disclosures of personal data, to request a restriction on its processing, or withdraw any consent, though such actions typically will not have retroactive effect. They also will not affect RoC’s ability to continue processing data in lawful ways (for example, if such user opts out of the use of such user’s e-mail for direct marketing, RoC might still decide to contact such user by e-mail regarding potential fraud on such user’s account).
The rights and options described above are subject to limitations and exceptions under applicable law, including, without limitation, the GDPR. In situations in which RoC processes personal data on behalf of a user, RoC may refer the request to the relevant user and cooperate with their handling of the request, subject to any special contractual arrangement with that user.
The Company is committed to the free exercise of these rights without fear of being denied the opportunity to use the Service. To exercise any right or make any request, please notify us at email@example.com or in accordance with the "CONTACTING US" section below. We will respond to your request in accordance with the applicable law that governs the collection, use and deletion of your data and information. The requested deletion will be as comprehensive as possible but is always subject to issues outside of our control, including applicable regulations and laws, your actions and the actions of third parties. It is important to note that we may retain a copy of the information for archival purposes and to avoid identity theft or fraud.
You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes applicable law. However, RoC encourages any such user to contact RoC first at firstname.lastname@example.org, and RoC will do its very best to promptly address such user’s issue(s) and resolve the concern(s).
Below is a list of our service providers with whom we may share user information and the services they generally provide.
Purpose of Data Sharing
Data security and archival services
Data science; user and product research
Data science; user and product research
On the Site, via the CONTACT US section, if available
or by phone:
For Consumers and Professionals: If you are in the US, call toll-free 800-RoC-1964
or please write to the following address:
Roc Opco LLC, 261 Madison Avenue, 16th Floor, New York, NY 10016
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