Last Updated: July 1, 2024

 

Rothco respects your concerns about privacy. This Policy Privacy Notice (“Policy”) describes the types of personal information we collect, how we use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe measures we take to protect the security of the information and you can Contact Us about our privacy practices. To make this Policy easy to find, we make it available on our homepage and at every point where personal information might be requested. Throughout this Policy, “we”, “us”, and “our” refers to Rothco, and “Website” or “Site” refers to Rothco.com, including mobile versions of those sites. The Policy applies to the information we obtain via your transactions and interactions with Rothco, including our website, www.Rothco.com, when you connect with us via telephone, and through third-party sources, including our advertising and social media networks.

 

Consent

Please review this Policy periodically. You should read this entire Policy before submitting information, including personal information, to us in any form or using our Site. Whenever you submit personal information to us, your consent to the collection, use, disclosure, share, sale, transfer, and storage of that information in accordance with this Policy.

 

Information We Collect

We collect personal information using three methods: (1) when you choose to voluntarily provide it; (2) using automated technology, including when you visit our Site or interact with our electronic advertisements or communications; and (3) using third party sources including but not limited to service providers, entities providing data analysis and analytics, social media and other entities.

 

We may collect personal data from customers both online and offline. Online, we may collect information through the Site, an affiliated site (such as a promotional microsite linked to our site), a Rothco page on a community website (such as Facebook or the like), when you interact with us through email, text messages, or through similar online avenues. On some pages, you may order products, make requests, submit product reviews, and register to receive materials or information and this information may also be used or collected. Offline, we may collect information through our sales associates at our Headquarters Location (such as email addresses for the purpose of sending electronic receipts). Our Policy applies to all information collected by or submitted to the Site, Rothco, or its employees as described herein.

 

To see a complete list of what we collect and how we use this data, see Table 1: Information Collected, Sources, and Business Purpose for Collection.

 

The types of personal information we collect includes:

·                Contact information, such as name, telephone number and postal and email address;

·                Rothco.com login credentials, such as password and security questions and answers;

·                Purchase history and merchandise preferences;

·                Payment information (including credit or debit card number, security code, expiration date and billing address);

·                Information provided by vendors and other entities that perform services on our behalf, including information services;

·                Photographs, such as if you choose to interact with us on social media sites;

·                Audio information, such as recorded phone lines and other technologies, where permitted by law;

·                Geolocation information; and

·                Other information you choose to provide, such as through our “Contact Us” feature, emails or other communications, social media pages, surveys, registration, and sign-up forms.

 

When you visit our Site, we may obtain certain information by automated means, such as cookies, web beacons, web sever logs and other technologies.

 

Cookies

Our Website uses “cookie” technology to improve the quality of your experience. A cookie is a small file that is placed onto an Internet user's web browser or device and is used to remember and/or obtain information about the user. Cookies store information that a website may need in order to personalize your experience and gather website statistical data. Any time you visit our Website to browse or to read or download information, we collect and store the name of the domain and host from which you access the Internet (for example, msn.com, google.com, etc.); the Internet protocol address of the computer you are using; the browser software you use and your operating system; the date and time you access our Website; and the Internet address of the website from which you linked directly to our Website. We use this information to measure the number of visitors to areas of our Website, and to help us make our Website more useful and interesting to our visitors.

 

We use information from cookies in the aggregate to analyze for trends and statistics, and then discard it. To find more information about cookies and for instructions on how to disable them please visit www.allaboutcookies.org or visit the help section of your browser. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.

 

Flash Cookies

Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

 

Web Beacons

Pages of our Website and our email may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that enable us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We may also use technologies to collect information about your online activities over time and across third party websites or other online services (e.g., behavioral tracking). Because there are not yet common industry-accepted “do-not-track” standards and systems, our Website does not respond to “do-not-track” signals.

 

Personal Information

The types of personal information collected include personal identifiers, financial and commercial information, and Internet and device information, including, without limitation, your name, address, email address, phone number, and credit/debit card information. We may collect information about your browsing history, search history, purchase behavior, IP address, device type, cellular carrier, location information, and other information regarding your interaction with a particular website, application, or advertisement, including the Website, when and after you use the Website.

 

We may combine information you give us with other information from Rothco sources or transactions, including without limitation: direct mail, catalogs, events, and automatic data collection sources. We may also combine that information with data that is publicly available and/or data from third parties.

 

How We Use The Information We Collect

We may use the personal information we collect to:

·                Provide our products and services;

·                Process and fulfill orders;

·                Communicate with you (including providing you with offers and other communications about our products and services), respond to inquiries, contact you about the status of an order, and offer customer support;

·                Establish and manage Rothco.com accounts;

·                Verify your identity;

·                Personalize your experience on our Site;

·                Advertise and market our products and services, including providing personalized advertising;

·                Administer participation in surveys, promotions, or other programs;

·                Establish and manage our business relationships;

·                Perform analytics (including website analytics, market research, trend analysis, financial analysis and anonymization of personal information);

·                Operate, evaluate and improve our business (including developing new products and services; managing our communications and customer service function; and performing accounting, auditing and other internal functions);

·                Maintain and enhance the safety and security of our Site, products and services and prevent misuse;

·                Exercise our rights and remedies and defend against legal claims;

·                Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and

·                Comply with and enforce applicable legal requirements, relevant industry standards and Rothco policies.  

 

For more detail about how information is collected and used, see Table 1: Information Collected, Sources, and Business Purpose for Collection below.

 

Email/Text Marketing

We will occasionally send out promotional emails to our previous purchasers relating to catalog and email signups. You may opt-in to receive emails from us by providing an email address during checkout at Rothco.com or by signing up within your Registered Account. If you no longer wish to receive email marketing communications from us, you may opt-out of receiving marketing-related emails by using the unsubscribe method provided in your communications (e.g., by clicking on the “unsubscribe” link in the mail to unsubscribe). Please note that unsubscribing from our promotional material will not prevent us from contacting you for other reasons, such as responses to customer service inquiries, or information about a plan type for which you have expressed interest in.

 

You may also choose to participate in certain text or SMS/MMS marketing. If you opt-in to such marketing, we may collect and use certain personal information, including phone number, email, product browsing behavior, purchase behavior, device type, cellular carrier, and location to contact you and provide you marketing communications or promotions, you may opt-out of receiving marketing-related messages by using the unsubscribe method provided (e.g., by relying “STOP” in the message to unsubscribe).

 

Information We Share

We may share information we collect about you with our affiliates and with our marketing partners. We may also share information we collect about you with third-party vendors and other entities to perform services on our behalf, such as website hosting, data analytics, advertising, customer service, payment processing and other services.

 

Detailed Description of Categories of Third Parties

Third Parties that Rothco may disclose your Personal Information to:

 

(a)             Service Providers/Subcontractors

Rothco may share your Personal Information with our subcontractors for certain business purposes. This information is provided in order for them to provide Rothco with services such as payment processing, advertising services, marketing partners, web analytics, data processing, IT services, customer support, customer product and service fulfillment, and other services such as for the purpose of auditing and fraud investigations.

(b)            Related Entities

Rothco may share Personal Information between and among Rothco, its subsidiaries, and affiliated companies for purposes of management and analysis, and other business purposes. For instances, Rothco may share your Personal Information with our subsidiaries and affiliated companies to expand and promote our product and service offerings.

(c)             Law Enforcement/Legal Authorities

Rothco may be required to disclose your Personal Information to third parties including law enforcement agencies when required to protect and defend our legal rights, protect the safety and security of users of our Services, prevent fraud, respond to legal process, or a request for cooperation by a government entity, as required by law.

(d) Corporate Transactions

In the event of sale, transfer, merger, reorganization, or similar event, Company may transfer your Personal Information to one or more third parties as part of that transaction with the business entities or people involved in the deal negotiation or transfer.

(e) With Your Consent

Company may share Personal Information about you with other third-party companies if you give us permission or direct us to share the information. Company will share Personal Information with authorized agents with whom you authorize Company to communicate. We do not sell and have not sold Personal Information, including your Sensitive Personal Information. Without limiting the foregoing, we do not sell the Personal Information, including the Sensitive Personal Information, of minors under 16 years of age. We do not knowingly “share” the Personal Information, including the Sensitive Personal Information, of minors under 16 years of age.

 

Third-Party Advertising and Analytics Disclaimers

We and/or third parties including advertising companies, social networking sites, and service providers on our behalf, use cookies, web beacons and other similar technology, to collect information for the purposes described in this Policy including advertising, analytics, online behavioral marketing, monitoring performance and improvement of our online services (traffic, errors, page load time, popular pages, etc.).

 

You can opt out of remarketing and targeting advertising as follows:

·                Google Analytics and Facebook Pixel: We use Google Analytics and Facebook Pixel to understand how our website, services, and products perform, how you use them, and to serve you with ads on third-party websites and social networking sites like Facebook.

To learn more about how Google processes your data, please visit: https://www.google.com/policies/privacy/.

 

To opt out of Google Analytics, please install the Google Analytics Opt-out Browser Add-on by visiting:  https://tools.google.com/dlpage/gaoptout.

 

To learn more about how Meta uses your data, please visit: https://www.facebook.com/policy.php.

 

 

Links to Other Sites

We provide links on occasion to other websites we think you may enjoy. These websites operate independently of Rothco and have established their own privacy and security policies. For the best online experience, we encourage you to review these policies before submitting any Personal Information to these websites.

 

Consent To Transfer

The Site is operated in the United States. Please be aware that any information you provide to us will be transferred to the United States. By using a Site from outside of the United States and/or providing us with your Personal Information through a Site, you consent to this transfer.

 

Retention of Data

We will retain your personal information (collected through offline and online methods) for as long as it is necessary for the purposes described in this Policy (Table 1: Information Collected, Sources, and Business Purpose for Collection). We will also retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

 

Intended Audience of Website; COPPA Compliance

We are in compliance with the requirements of the Children’s Online Privacy Protection Act (“COPPA”). We do not knowingly collect information from minors in the United States or elsewhere with or without the consent of their parents or guardians. Children (under the age of 16) are not eligible to use the Website unsupervised, and we ask that children do not submit any personal information to us. If you are not 16 or older, you should not visit or use our Website or social media accounts. If you become aware that a minor has provided us with personal information without appropriate consent, then please contact us using the details below so that we can take the appropriate steps in accordance with our legal obligations and this Policy.

 

Our Commitment to Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place and maintain appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect. The transmission of information via the Internet is not completely secure. Although we strive to protect your personal information in accordance with this Policy, we will not be liable for disclosure of personal information obtained due to errors in transmission or security breaches.

 

If You Are a Citizen of Canada

Canadian citizens, except under circumstances defined by law, are entitled to access their Personal Information collected by us by writing to us at the address set out in the Contact Us section below. We may ask you to pay an administrative fee for accessing or copying your information, but will inform you of the anticipated charges and confirm that you want us to proceed before processing your request. If you believe that the Personal Information about you that we have collected is incomplete or inaccurate, we will correct the information upon verification that an omission or error exists and that the Personal Information relates to the person requesting the correction. If you would like to request additional information about our Personal Information management practices or access or correct or have us investigate any matters in relation to your Personal Information, please contact us using one of the methods set out in the Contact Us section below.

 

If You Are a Resident of California

If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your personal information with third parties for the third parties' direct marketing purposes. California law provides that existing customers have the right to submit a request to us once a year at the designated address for and receive the following information:

·                the categories of information we disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year;

·                the names and addresses of third parties that received such information; and

·                if the nature of a third party's business cannot be reasonably determined from the third party's name, examples of the products or services marketed.

 

You are entitled to receive a copy of this information in a standardized format, and the information will not be specific to you individually. Our designated email address for such requests is Privacy@Rothco.com.

 

If You Are a Resident of California, Colorado, Connecticut, Utah, Virginia, Oregon, or Texas

If you are a resident of California, Colorado, Connecticut, Utah, Virginia, Oregon, or Texas, the following provisions may apply to our processing of information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”) subject to the California Consumer Privacy Act of 2018/ Privacy Rights Act, the Colorado Privacy Act, the Connecticut Personal Data Privacy Act, the Utah Consumer Privacy Act, the Virginia Consumer Data Protection Act, the Oregon Consumer Privacy Act, and  the Texas Data Privacy and Security Act (collectively the “Privacy Laws”).

 

Colorado, Connecticut, Utah, Virginia, Oregon and Texas define a ‘Consumer’ as a resident of the state who is acting in an individual or household capacity, but this excludes state residents who are acting in an employment capacity (as one of our current, former or prospective employees) or in a commercial capacity (as an employee, owner, director, officer, etc. of an entity communicating with us in that context). As a result, if you reside in one of these states and have interacted with us in an employment or commercial capacity you are not provided the rights described below by the Privacy Laws.

 

California defines a ‘Consumer’ as any resident of the state regardless of the capacity in which they interact with us.

 

For Consumers, the provisions of this section prevail over any conflicting provisions of this Privacy Statement. We adopt this section of our Privacy Statement to comply with the Privacy Laws of and any terms defined in the Privacy Laws have the meaning set forth in the law of your state of residence when used in this section.

 

 

Table 1: Information Collected, Sources, and Business Purpose for Collection

The following table lists the categories of Consumer personal information, whether we have collected information in the category during the past 12 months, the sources of the information, and the business purposes for which we collect and use the information. The categories of information include information we collect from our website visitors, registered users, employees, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals. For instance, we may collect different information from applicants for employment or from vendors or from customers.

 

	Category of Information	Collected?	Source	Business purposes for use*
1	Identifiers. (name, alias, postal address, email address, phone number, fax number, account name, Social Security number, driver's license number, passport number, unique personal identifier, IP address)	Yes	Individuals submitting information to us; information we automatically collect from site visitors; information we may receive from third-parties.	Auditing relating to transactions; security detection, protection and enforcement. Functionality debugging/error repair; ad customization; performing services for you; internal research and development; quality control.
2	Protected Information. (name with: Social security number, driver’s license or state ID number, financial account, medical, health, and health insurance information, username and password)	Yes	Individuals submitting information; employment applications; employees.	Auditing relating to transactions (employee administration); security detection, protection  and enforcement; performing services for you; quality control.
3	Protected antidiscrimination classification information. (Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)).	Yes	Individuals submitting information.	Auditing relating to transactions (employee and vendor administration); compliance with law.
4	Commercial Information. (transaction history, products/services purchased, obtained or considered, product preference)	Yes	Individuals submitting information; information we automatically collect from site visitors; information we may receive from third-party marketing or data partner	Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair; ad customization; performing services to you; internal research and development; quality control.
5	Electronic network activity. (browsing or search history, website interactions, advertisement interactions)	Yes	Information automatically collected from site visitors.	Auditing relating to transactions; security detection, protection and enforcement; functionality debugging/error repair; ad customization; performing services for you; internal research and development; quality control.
6	Audio, video or similar information. (customer service calls, security monitoring)	Yes	Individuals submitting information; information we collect for security purposes.	Security detection, protection and enforcement; functionality debugging/error repair; performing services for you; internal research and development; quality control.
7	Biometrics.	No	Not collected.	Not Collected.
8	Geolocation.	Yes	Information we automatically collet from site visitors.	Auditing relating to transactions; ad customization; performing services for you; internal research and development.
9	Professional, educational or employment related information.	Yes	Information submitted by individuals; information received from third parties in connection with vendor or employment status or applications; information we observe in connection with vendor or employment oversight.	Auditing relating to transactions (employee and vendor administration); security detection, protection and enforcement; performing services for you; internal research and development; quality control; compliance with law.
10	Non-public educational information. (Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records).	No	Not collected	Not collected
11	Sensitive Personal Information. (social security, driver’s license state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, genetic data, biometric information, health, sex life or sexual orientation.)	Yes	Information submitted by individuals; information received from third parties in connection with vendor or employment status or applications; information we observe in connection with vendor or employment oversight.	Identity verification; employment and benefits administration; vendor oversight; security detection, protection and enforcement; compliance with law.
12	Inference from above. (Preferences, characteristics, behavior, attitudes, abilities, etc.)	Yes	Internal analytics	Auditing relating to transactions; security detection, protection and enforcement; ad customization; performing services for you; internal research and development; quality control.

 

* The Business Purposes for Use Include:

(a) Performing services for you:

·                To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;

·                To assist you in completing a transaction or order;

·                To allow tracking of shipments;

·                To prepare and process invoices;

·                To respond to queries or requests and to provide services and support;

·                To provide aftersales customer relationship management;

·                To create and manage our customer accounts;

·                To notify you about changes to our services and products;

·                To administer any promotion, contest, survey, or competition;

·                To provide you information regarding our products and services; and

·                To offer our products and services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly.

(b) Advertising Customization

·                For marketing and promotions we believe you may find of interest and to provide you, or allow selected third parties to provide you, with information about products and services that may interest you.

(c) Auditing Relating to Transactions, Internal Research and Development

·                To provide for internal business administration and operations, including troubleshooting, Site customization, enhancement or development, testing, research, administration and operation of our Sites and data analytics;

·                To create products or services that may meet your needs; and

·                To measure performance of marketing initiatives, ads, and websites “powered by” another company on our behalf.

(d) Security Detection, Protection and Enforcement; Functionality Debugging, Error Repair

·                As part of our efforts to keep our Sites safe and secure;

·                To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Sites, for example, by requesting verification information in order to reset your account password (if applicable);

·                To ensure the physical security of our premises through the monitoring of surveillance images;

·                To resolve disputes, to protect the rights, safety and interests ourselves, our users or others, and to comply with our legal obligations.

(e) Quality Control

·                To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures,

·                To develop and improve our products and services, for example, by reviewing visits to the Sites and various subpages, demand for specific products and services and user comments.

 

Disclosing Personal Information

From time to time we disclose Consumer information as described below. This includes disclosing information to service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partner); affiliated companies; strategically aligned businesses; professional advisers (such as lawyers, bankers, staffing partners, auditors and accountants); and, when required by law, to regulators or law enforcement.

 

A.              Disclosure of Personal Information for a Business Purpose

We may disclose your personal information to service providers and others for a business purpose. The business purposes are listed above. When we disclose Consumer personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we may have disclosed the following categories of Consumer personal information to service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partner); affiliated companies; strategically aligned businesses; professional advisers (such as lawyers, bankers, staffing partners, auditors and accountants); and, when required by law, to regulators or law enforcement. Not all information is disclosed to the above; photographs posted by site users are available to the public:

·                Category 1: Identifiers

·                Category 2: Protected Personal Information

·                Category 3: Protected anti-discrimination classification information.

·                Category 4: Commercial Information

·                Category 5: Electronic network activity information

·                Category 6: Audio, video or similar information

·                Category 8: Geolocation

·                Category 9: Professional or employment-related information

·                Category 11: Sensitive personal information

·                Category 12: Inferences

 

B.              Disclosing Personal Information in Sale Arrangements

We do not sell personal information for monetary consideration but we may transfer Consumer information to a third party that provides us with services such as helping us with advertising, data analysis and analytics, and security, which may fall under the definition of for “other valuable consideration” and which may therefore be considered a “sale” under some of the Privacy Laws. We do not sell the personal information of Consumers we actually know are less than sixteen (16) years of age. Please see below for opting out of having your information sold. In the preceding twelve (12) months we may have disclosed the following categories of information for a business purpose which falls within the definition of a ‘sale.’

·                Category 1: Identifiers

·                Category 4: Commercial Information

·                Category 5: Electronic network activity information

·                Category 8: Geolocation

·                Category 12: Inferences

 

C.              Sharing Personal Information for Behavioral or Cross-Marketing or Targeted Marketing

Sharing Consumer personal information means making it available to a third party so that they can use it to display targeted or cross-context behavioral advertisement to you. Cross-context behavioral or targeted advertising means that we display an advertisement to you that is selected based on personal information about you that we obtained or inferred over time from Consumers’ activities across other companies’ websites, applications or online services that we use to predict Consumers’ preferences or interests. Targeted advertising does not include using Consumers’ interactions with us or information that Consumers provide to us to select advertisements to show them. In the preceding twelve (12) months, We have shared the following categories of personal information of non-minors for behavioral or cross context or targeted advertising.

·                Category 1: Identifiers

·                Category 4: Commercial Information

·                Category 5: Electronic network activity information

·                Category 8: Geolocation

 

Consumers’ Rights and Choices

The Privacy Laws provide Consumers in California, Colorado, Connecticut, Utah, Virginia, Oregon, and Texas with specific rights regarding their personal information. This section describes Consumers’ rights under the Privacy Laws, explains how to exercise those rights, and provides information about the response timing and format and your rights to appeal our decisions.

 

A.              Access to Information and Data Portability Rights

Consumers have the right to request that we disclose certain information to Consumers about our information collection and disclosure practices. Consumers also have the right to request a copy of the specific pieces of personal information we collected about them. Once we receive and confirm a verifiable Consumer request, we will disclose:

·                The categories of personal information we collected about you, the sources of the information, our business or commercial purpose for collecting the information and whether the information was disclosed for a business purpose, shared or sold.

·                The categories of information we disclosed for a business purpose and the categories of information we sold or shared during the prior 12 months along with the categories of recipients of such information.

·                The specific pieces of personal information we collected about you during the prior 12 months, or, at your option, since January 1, 2022. Please note that this disclosure will not include data generated to help ensure security and integrity or as prescribed by regulation. We will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.

 

B.              Consumers’ Deletion Request Rights

Consumers have the right to request that we delete any of your personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm a verifiable Consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

·                Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

·                Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities and to help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.

·                Debug products to identify and repair errors that impair existing intended functionality.

·                Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

·                Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

·                Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s ability to complete such research, if you previously provided informed consent.

·                Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.

·                Comply with a legal obligation.

·                Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

C.              Consumers’ Information Correction Rights

Consumers have the right to request that we correct information that we hold which is inaccurate. We will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections. In some cases, for instance if you have an account with us, you can update your information by logging into your account.

 

D.              Consumers’ Opt-Out Rights

·                Do Not Sell My Personal Information. If you are 16 years of age or older, you have the right, at any time, to direct us to not sell your personal information. We do not sell the personal information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

·                Do Not Share My Personal Information; Targeted Advertising. Consumers have the right to opt out of having their personal information shared for cross context behavioral advertising purposes and having their information used for targeted advertisements. When Consumers opt out we will not share their personal information with others that they can use to send the Consumer targeted advertisements and we will not use information we obtain over time from Consumers’ activities with third party companies to show advertisements. We can still use information that we receive from your interactions with us to select advertisements we think may be of interest to you.

·                Limit Processing of Sensitive Personal Information. Consumers have the right to tell us not to process Sensitive Personal Information for any purpose other than the purpose for which we originally collected it.

·                Consumer Profiles. Consumers have the right to direct us not to engage in profiling using their personal information. Profiling is any automated processing performed on personal information that is used to evaluate, analyze, or predict personal aspects related your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

 

Exercising Consumers’ Rights

A.              Making a Consumer Request

Consumers may make a verifiable Consumer request for access or data portability only twice within a 12-month period. All other requests may be made at any time. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.

·                Access, Correction and Deletion. To exercise the access, correction, and deletion rights Consumers may contact us by calling us at +1-631-585-9446 or emailing us at Privacy@Rothco.com. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. However, you may request that we disclose the required information beyond the 12-month period, and we will honor that expanded request unless doing so would involve a disproportionate effort. Your right to request required information beyond the 12-month period, and our obligation to provide that information, shall only apply to personal information collected on or after January 1, 2022.

·                Opt-Out Rights. To opt out of the sale of your personal information or the sharing of your personal information or to ask us to limit processing of your Sensitive Personal Information, you may submit a request to us by emailing us at Privacy@Rothco.com. You may also call us at +1-631-585-9446.

·                You may also opt out by activating a user-enabled global privacy control, such as a browser plug-in or privacy setting, device setting, or other mechanism, that communicates or signals your choice to opt-out of the sale and sharing of personal information. When we receive such a signal we will stop setting third party, analytics, or advertising partner cookies on your browser. This will prevent the sale or sharing of information relating to that specific device through cookies to our advertising or analytics partners. This option does not stop all sales or sharing of your information because we cannot match your device’s identification or internet protocol address with your personally identifiable information like your name, phone number, email address or ZIP Code. If you delete cookies on your browser, any prior do not sell or do not share signal is also deleted and you should make sure that your user-enabled setting is always activated.

 

B.              Our Responses.

We will acknowledge receipt of your request for access, correction or deletion within 30 business days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time.

 

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance (e.g. Microsoft Excel file and/or Adobe PDF file).

For requests for deletion of your information, please understand that Privacy Laws permit us to retain certain information and not delete it under certain circumstances noted above in the description of Information Deletion Request Rights.

 

For requests that we not sell or share your information or limit processing or Sensitive Personal Information we will comply with your request promptly, and at least within 30 business days. Once we receive your request we will wait at least 12 months before asking you to reauthorize personal information sales or sharing.

 

We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.

 

We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Appealing Denied Requests

You have the right to appeal our decision to deny any of your privacy rights requests above. Within 60 days of receipt of your appeal (45 days for Colorado residents and Oregon residents), we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

We will respond to you in writing within 60 days explaining the reasons for our decisions. If we deny your appeal, you can contact your state Attorney General at:

 

Colorado residents:

Office of the Attorney General

Colorado Department of Law

Ralph L. Carr Judicial Building

1300 Broadway, 10th Floor

Denver, CO 80203

720-508-6000

 

Connecticut residents:

Office of the Attorney General

165 Capitol Avenue

Hartford, CT 06106

860-808-5318

 

 

 

Utah residents:

Utah State Capitol Office Mailing Address

Office of the Attorney General

PO Box 142320

Salt Lake City, UT 84114-2320

General Office Number:

1-801-366-0260

Virginia residents:

Office of the Attorney General

202 North Ninth Street

Richmond, Virginia 23219

804-786-2071

 

California residents: (not available)

Oregon residents:

Office of the Attorney General

Oregon Department of Justice

1162 Court St. NE

Salem, OR 97301-4096

503-378-4400

 

Texas residents:

Office of the Attorney General

PO Box 12548

Austin, TX 78711-2548

512-463-2100