We, Range of Motion Products, LLC (“us”, “we” or “our”) operate the websites www.iRolflex.com and www.RolflexPro.com (the “Service”).
Below are our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
Service: Service are the websites operated by Range of Motion Products, LLC (www.iRolflex.com and www.RolflexPro.com).
Personal Data: Personal Data means data or information about a living person who can be identified from that data (or from those and other information either in our possession or likely to come into our possession).
Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies: Cookies are small pieces of data stored on your device (computer or mobile device). Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which
INFORMATION COLLECTION AND USE
We collect several different types of information for various purposes to provide and improve our Service to you.
TYPES OF DATA COLLECTED
While using our Service, we may ask you to provide us with certain personally identifiable
information that can be used to contact or identify you (“Personal Data”). Such personally
identifiable information may include, but is not limited to:
- Email Address
- First and Last Name
- Phone Number
- Address, City, State, Province, Zip/Postal Code
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. However, you may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
We may also collect information on how the Service is accessed and/or used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookie Data
Examples of Cookies we use:
- Session Cookies: We use Session Cookies to operate our Service.
- Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
- Security Cookies: We use Security Cookies for security purposes.
Use of Data
We, Range of Motion Products, LLC, use the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support or service
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and/or general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data under General Data Protection Regulation(GDPR)
We, Range of Motion Products, LLC, may process your Personal Data because:
- We need to notify you of the status of the order that you placed with us.
- You have given us permission to do so.
- The processing is in our legitimate interests and it’s not overridden by your rights.
- For payment processing purposes.
- To comply with the law.
Retention of Data
to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of Data
DISCLOSURE FOR LAW ENFORCEMENT
Under certain circumstances, Range of Motion Products, LLC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
We, Range of Motion Products, LLC, may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Range of Motion Products, LLC
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
“Do Not Track” Signals
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Range of Motion Products, LLC aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us a firstname.lastname@example.org.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Range of Motion Products, LLC relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out
Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out
Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page:
https://www.facebook.com/help/164968693837950. To opt-out from Facebook’s interest-based ads follow these instructions from Facebook:
https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance.
You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA (http://www.aboutads.info/choices/), the Digital Advertising Alliance of Canada in Canada (http://youradchoices.ca/) or the European Interactive Digital Advertising Alliance in Europe (http://www.youronlinechoices.eu/), or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit
Facebook's Data Policy: https://www.facebook.com/privacy/explanation
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from a child or children without verification of parental consent, we will take steps to remove that information from our servers.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this
FOR CALIFORNIA RESIDENTS
Personal Information does not include:
- Publicly available information we obtain from government records
- de-identified or aggregated consumer information.
Information We Collect
We have collected the following categories of Personal Information from consumers within the last twelve (12) months:
Identifiers: Name, email address, mailing address, shipping address, phone number or other similar identifiers.
Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Geolocation data: State and country location. Internet or other electronic network activity information: IP address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences. Sensory data: Audio, electronic, visual, or similar information.
Inferences drawn from the above: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Categories of Sources: We obtain Personal Information provided voluntarily by you or a family member when you purchase our products or submit other similar forms directly to us or our affiliates by mail, email, by telephone, or via our websites and mobile applications. We also gather it from written or verbal inquiries submitted by you, surveys, transactions, and from online interactions with you.
We also collect information from third parties and publicly available sources, which include data service providers, social media services, advertising and market research firms, joint marketing partners, employers and group plan sponsors, and consumer reporting agencies.
Business Purposes for Collection of Personal Information: Collecting and using Personal Information is necessary to our business as a consumer products company in order to develop, enhance, and administer our products and services, respond to your requests, inquiries and concerns, inform and educate you about our company, products and/or events, and for advertising and marketing purposes. It also helps us to confirm your identity for certain transactions you request or that are initiated on your behalf, improve our website and mobile application user experience, authenticate users, prevent and detect fraud and potential security issues, and fulfill our legal and regulatory obligations such as tax reporting.
DISCLOSURES OF PERSONAL INFORMATION
Your Personal Information may have been disclosed to:
- You, your authorized representatives, legal agents, and other persons acting on your behalf or to whom you ask, instruct and/or authorize us to disclose your Personal Information,
- Our contracted service providers who provide a service to or on behalf of Range of Motion Products, LLC, including analytics service providers, payment providers and website partners,
- Our auditors, consultants, accountants, attorneys and others providing professional advice to Range of Motion Products, LLC,
- Other Range of Motion Products, LLC affiliates,
- Business partners of Range of Motion Products, LLC,
- Applicable governmental, regulatory, supervisory, law enforcement, tax or similar authorities or industry bodies,
- Any other person or entity that Range of Motion Products, LLC reasonably thinks is customary, necessary or advisable for the business purposes disclosed in our Privacy
Policy or to whom Range of Motion Products, LLC is obliged by applicable law or
regulation to make the disclosure,
- Any other party where Range of Motion Products, LLC has obtained your consent or authorization.
BUSINESS PURPOSES FOR DISCLOSURE OF PERSONAL INFORMATION
Our business purposes for the disclosure of Personal Information are:
- To advertise and market to you, and to consumers who are similar to you,
- To perform services on our behalf, including providing customer service, processing or fulfilling orders, account maintenance, processing payments, and quality control,
- For risk management purposes, identity verification, information security, fraud detection and prevention,
- Undertaking internal research, operational efficiencies and improvements, product enhancements, and business development purposes,
- In connection with legal proceedings, such as responding to a subpoena or court order,
- To demonstrate compliance with our regulatory obligations,
- To report tax information to relevant tax authorities,
- In the event of any planned or actual company reorganization, merger, sale or transfer of our business.
RIGHT TO KNOW
You have the right to request that we disclose certain information to you about our collection of your Personal Information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
- The categories of Personal Information we have collected about you,
- The categories of sources from which we have collected your Personal Information,
- Our business or commercial purpose(s) for collecting or sharing your Personal Information,
- The categories of third parties with whom we have shared your Personal Information, and
- The specific pieces of Personal Information we have collected about you.
Please note that even if your request is validated, we will not at any time disclose sensitive information such as a consumer’s financial account number, health insurance or medical identification number, account password, or answers to security questions. You have the right to request that we disclose certain information to you about our disclosures of your Personal Information to third parties. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
- The categories of Personal Information we have collected from you,
- The categories of Personal Information that we disclosed about you for a business purpose.
RIGHT TO OPT-OUT OF SALE
We do not monetize your personal information; however, we sometimes share information with unaffiliated third parties we collaborate with or that provide offers that we think may be of value to you, or with data cooperatives. This sharing of information may be considered a “sale” under California law.
RIGHT TO DELETE
You have the right to request that we delete certain Personal Information we collected from you. However, in many cases we cannot delete all or some of it due to our regulatory obligations to retain certain information, or as required or permitted by other applicable laws, such as for fraud prevention and similar purposes.
RIGHT TO NON-DISCRIMINATION
We will not discriminate against you for exercising your rights under the CCPA, such as denying you products and/or services, charging you different rates or prices including use of discounts or penalties, or suggesting or providing a different level of service or quality of products to you.
HOW TO EXERCISE YOUR CCPA RIGHTS
To submit a request to exercise any of your rights provided in this notice, please contact us at email@example.com and use “CCPA REQUEST” in the subject line. We must be able to verify your identity before we take action on your request. Please provide sufficient information to assist us, including your name and shipping address and transaction date. Also, please let us know if there is anything specific that you are requesting. You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent, we require that your authorized agent provides written proof to us that he or she is authorized to act on your behalf, and we may also require your authorized agent to verify his or her own identity. To appoint an authorized agent, please contact us at firstname.lastname@example.org.
Effective Date: May 1, 2020