For purposes of the EU General Data Protection Regulation (the “GDPR”) the data controller is RSSC, PLLC, 135 Sullys Trail, Suite 5, Pittsford, New York, 14534.
RSSC’s Privacy Principles
RSSC follows the following principles in order to protect your privacy:
– We do not collect any more personally identifiable information about you than is necessary;
Information We Collect
We collect personally identifiable information from you if you request information from us, sign up to join our email lists, register for an account, participate in our promotions, such as contests and sweepstakes, take our surveys, use or purchase our Products and Services, contact us about a purchase, or email, call or otherwise communicate with us.
In order for you to initiate or complete a purchase from us, we request certain personally identifiable information from you on our order form, including your contact information (such as name, email or shipping address) and financial information (such as credit card number, expiration date).
If you purchase a product or service for someone else, we will also collect the name and address of that person so that we can process your order and ship the products, as applicable. When you provide us with this information we will only use it for the specific reason for which it is collected.
When Visitors or Members download, install and use RSSC services on their mobile phone or other wireless telecommunications device, RSSC automatically gathers information, including without limitation, carrier providers, unique device identifiers, geolocation information (if allowed by the user), the types of mobile devices accessing the services, and the types of operating systems accessing the services (collectively, “Mobile Device Data”). A unique device identifier is a string of alphanumeric characters (similar to a serial number) used to uniquely identify and distinguish each mobile phone or other wireless communications device. Location services can be enabled or disabled at any time, through the settings on your mobile device. RSSC uses Mobile Device Data to understand usage patterns and to improve our Products, Services, and functionality of our Site.
RSSC automatically receives and records information on our server logs from your browser, including your IP address, domain type, browser version, service provider, cookies, and the pages you request. This data is used in the aggregate. We link this automatically-collected data to personally identifiable information.
How We Use Your Information
Information we collect may be used in the following ways:
– To notify you of updates to our Site or any Products or Services we offer.
– To respond to your requests or inquiries.
– To process and complete your transactions, including, as applicable, customer service, order confirmation, billing, delivering Products or Services, and otherwise fulfill our contractual obligations to you.
– To provide you with newsletters, articles, or programs, Products, or Services, alerts and announcements.
– To share offers from other companies with you.
– To conduct market research.
– To analyze transactions and purchase histories to improve our products, services, programs, and other offerings.
– As necessary to verify and validate your identity.
– To keep records of our interactions with you if you place an order or otherwise deal with our representatives.
– To prevent, investigate or provide notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personally identifiable information, our Site or data systems.
– To carry out our obligations and enforce our rights.
– To fulfill any other purpose for which you provide your personally identifiable information to us.
You have the right to request a copy of any personally identifiable information that we hold about you. If you would like a copy of your personally identifiable information, please contact us using the contact information below. We may request proof of your identity before sharing such information. If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information by emailing us at email@example.com.
You may ask us to delete the personally identifiable data we hold about you in certain circumstances. It may not be possible for us to delete all of the information we hold about you where we are fulfilling a transaction or have a legal basis to retain the information, however, please contact us to discuss how we can assist you with your request.
When we process your information on the basis that you have consented to such processing, you have the right to withdraw your consent or ask us to stop or restrict processing the personally identifiable information we have about you, at any time by emailing us at firstname.lastname@example.org.
You may also ask us to transfer your personally identifiable information to a third party in certain circumstances. If you would like any further information about your rights or how to exercise them, please contact us.
Please direct any questions, including any requests to exercise your legal rights, to email@example.com.
If you are in the European Union, you have the right to make a complaint at any time to the relevant data protection authority in your country.
We will retain your information for as long as your account is active or as needed to fulfill your requests, provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements.
If you receive emails from us about new or existing RSSC Products, Services and special offers specific to you, you can unsubscribe to our emails by clicking “unsubscribe” within each email. You may not opt-out of service-related communications, which are not promotional in nature.
Cookies and Other Tracking Technologies
As is true of most Sites, we gather certain information automatically and store it in log files. This information may include 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 site.
We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. We use session cookies to track your login status. This cookie is only ever transmitted over HTTPS. A persistent cookie remains on your hard drive for an extended period of time. We use persistent cookies to determine from where you were referred to our Sites so that we may provide commissions or referral fees, and recognize the last user ID that you used to log in. We may set and access RSSC cookies on your computer; cookies are required to use the Sites.
You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. Please go to www.aboutcookies.org for more information on cookies, including how to disable them. If you choose to disable cookies, it may limit your use of certain features or functions on our Sites or service. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
Behavioral Targeting / Re-Targeting
Disclosure of Personally Identifiable Information
Our practices with respect to the disclosure of personally identifiable information include the following: Consent. We may disclose your personally identifiable information to third parties with your express consent.
Agents/Service Providers. We use third-party service providers to assist us in providing our Services and Sites, including database backup providers to protect our data, and fraud prevention services. We may disclose your personally identifiable information to third parties who complete transactions or perform services on our behalf or for your benefit. We may utilize the services of third parties to verify customer data, or to supplement other information we have collected. We may also contract with third parties to host our Sites and to conduct market research. All service providers are authorized to use your personally identifiable information only as necessary to provide their respective services to us, and are obligated to protect your personally identifiable information under contract terms which are no less protective than those set forth in this Policy.
Legal Process. We may disclose your personally identifiable information as required by law, such as to comply with a subpoena or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
You will be notified via email and/or a prominent notice on our Sites of any change in ownership or uses of your personally identifiable information, as well as any resulting choices you may have regarding your personally identifiable information.
The security of your personally identifiable information is important to us. When you enter sensitive information such as credit card number on our registration or order forms, we encrypt that information using SSL.
We follow generally accepted industry standards to protect the personally identifiable information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personally identifiable information, we cannot guarantee its absolute security.
The information we collect about you is stored in limited-access servers. We maintain safeguards to protect the security of these servers and your personally identifiable information. We retain personally identifiable information only as long as necessary to complete a purchase, thwart fraud, or provide customer service.
Links to Other Sites
If you click on a link to a third-party site you will leave our site and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personally identifiable information by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as us. We encourage you to review the privacy policies of any other site you visit or service provider from whom you request services.
Wherever you use our Site or access our Services, you understand and acknowledge that we may transfer, process, and store information about you in the United States and other countries, both within and outside of the European Economic Area. The countries to which we transfer your personal information may have different data protection laws than those in the country in which you reside.
Matthew Buffan, DC