Effective Date: 9/10/2021
This privacy statement covers all Personal Data (information that relates to or that can be used to identify you) by Retail Solutions, LLC at its website www.RetailSolutions1.com (the “Site”) and its Direct Commerce Platform (the “Platform”). This Policy does not describe information collection policies and practices of websites and platforms that we do not provide, own, or control, including those linked to or integrated with our Site or the Platform (“Third Party Brand(s)”). It also does not cover information you may choose to share with other users of the Site.
We encourage you to review this Policy periodically. Your use of the Site or the Platform constitutes your consent to the terms contained herein. We will periodically update this Policy, and any changes will be reflected here. We will notify existing customers of any material changes by email or via your account.
If you have any questions about this Policy or how we use your Personal Data, please feel free to contact us at email@example.com.
What personal data do we collect?
When using the Retail Solutions Site or Platform, we may collect information you voluntarily share with us, including any content, record, or electronic communication of any kind, including without limitation:
• contact information, including identifiers such as name, full shipping address, country of residence, phone number, username, password, and email address.
• financial information related to payment or requested credit account, including name, email address, billing address, credit card information, banking information, telephone number, and other information necessary to complete a transaction or purchase.
• commercial information, such as a record of products or services purchased, and the date and time the transaction occurred.
• inferences, such as product and service preferences including your preference in receiving marketing information received from our third parties, product feedback and survey responses.
• internet information, such as IP address, GPS, login data, browser, time zone, geographical location and any other unique identifier (a set of numbers or characters assigned to your computer, mobile phone or other device used when you are on the internet) tied to your device when visiting our Site or Platform, and information about how you use and interact with our Site or Platform.
How do we collect your personal data?
When you interact with us
We collect your Personal Data when you interact with the Site or Platform, including when you:
• make a purchase on the site or platform
• subscribe to emails / newsletters
• request services or seek support
• participate in promotions and surveys
• give feedback about products, services, or website
Cookies, Web Beacons and other technologies
• automated technologies or interactions
• cookies, pixel tags, embedded scripts, LSOS, Priority Code
Cookies are stored on your computer’s hard drive and identify your web browser and the activities of your computer on the Site, Platform and other websites. Most browsers accept cookies automatically, but you may disable them. Cookies help us facilitate efficient Site and Platform navigation, improve your experience on the Site and Platform, facilitate your shopping session, allow us to take note of visits to the Site and Platform and show relevant ads on our Site and Platform and across the Internet.
Action tags, also known as web beacons or single pixel GIFs, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you. Any portion of the Site or Platform, including advertisements or emails sent on our behalf, may contain action tags. Action tags can be used to count Site or Platform users, to deliver co-branded services, or to determine whether email messages have been opened or acted upon. Action tags may be used to conduct research on behalf of certain clients, to compile statistics for advertising purposes, for auditing purposes, or to report certain aggregate information.
By using these identifiers together, we are able to gather information to improve the Site and Platform and measure the effectiveness of our advertising and marketing campaigns. Embedded URLs perform many of the same functions as cookies and we may utilize them as a tracking tool to collect Non-Personal Data. Embedded URLs are exhibited as plain text or encoded extensions to the URL that appear in the browser address or location toolbar. They provide limited Non-Personal Data about navigation on the Site and Platform during the current session.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can obtain information about blocking and deleting cookies from your browser’s settings. You may also manage preferences regarding cookies by visiting https://allaboutcookies.org/manage-cookies/.
From Third Parties
We may collect information from our third party providers, including:
• analytics providers
• advertising networks
• identity verification services
• credit reporting agencies (as applicable)
• payment & delivery services
How does Retail Solutions use the personal data we collect?
We may use your Personal Data:
To provide the Site and Platform to you, including:
• to determine whether our services are available in your country;
• to determine your preferred language;
• to process your registration and account creation with the Site or Platform, including verifying your contact information is active and valid;
• to identify you as a user in our system;
• to process transactions you initiate, process payments and provide accurate billing and shipping; and
• to improve our website, product and service offerings, and develop new products and services.
To communicate with you, including:
• to provide you with information, products or services that you have requested or agreed to receive;
• to send you administrative e-mail, such as order confirmations, order status updates, security, or support and maintenance advisories;
• to bill you for products or services
• to notify you about changes to our service; and
• to contact you with regard to your use of the Site or Platform and, in our discretion, changes to the Site’s or Platform's policies or functionality.
To personalize your experience on the Site and Platform, including:
• to customize our Site and Platform and its contents to your interests and your device;
• to customize and tailor your experience on the Site or Platform, for example, by displaying content that we think you might be interested in; and
• to improve the quality of experience when you interact with our Site and Platform for internal business purposes.
To comply with our legal obligations and protect our other users, including:
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
• to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
OPT-OUT OR UNSUBSCRIBE TO MARKETING MESSAGES
We do not send any direct marketing emails. You may choose to opt-in to receive direct marketing emails from the Third Party Brands on the Site or Platform, in which case we will send that information to the respective brand. In the future, if you do not wish to have your e-mail address or other contact information used for promotional purposes, you should follow that brand’s process in order to opt-out.
Please note that we reserve the right to send you certain communications relating to your account (for example, administrative and service announcements, shipping notices, and order confirmations) and these transactional account messages may be unaffected if you opt-out from marketing communications by the Third Party Brand.
CHOOSING NOT TO SHARE PERSONAL DATA
You may choose not to provide us with any Personal Data. In such an event, you may still be able to access and use some portion of the Site or Platform; however, you may not be able to access and use those portions that require your Personal Data.
Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
The Site and Platform are not directed to children under the age of 18. We do not knowingly collect any personal information from children under the age of 18. If we learn that a child under the age of 18 has provided us with personal information, or that such personal information has otherwise been inadvertently collected, we will delete it in accordance with applicable law.
Who do we share your information with?
Service Providers. As part of Retail Solutions’ operation of its Site and its Platform, we may contract with third-party providers to perform certain functions, including fulfilling orders, processing payments, and customer service. These third parties may have access to Personal Data to the extent necessary to permit them to assist Retail Solutions in performing the functions set forth above. Any such third party that processes your information for these purposes agrees to do so in accordance with our instructions and in accord with this Policy.
Retailers. Retail Solutions provides shopping cart and other check-out services to its retailer clients. We share your shipping, checkout, and other-related information to our clients when you make a purchase on their websites.
Merger, Sale or other Transaction. We may disclose information about you to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or disposition of all or a portion our assets. The successor organization’s use and disclosure of your personally-identifiable information will continue to be subject to this policy unless (i) a court orders otherwise, for example a bankruptcy court; or (ii) the successor organization gives you notice that your Personal Data will be subject to the successor organization’s own policy, along with an opportunity for you to opt out (which may cause you not to be able to continue to use our Services). If you submit Personal Data after such a transfer, that information may be subject to the successor entity’s policy.
Third Party Sites
You have the right to request that we: provide you with access to your Personal Data, correct your Personal Data or Erase your Personal Data.
We will take reasonable steps to verify your identity before granting access to your Personal Data
You may access and correct your online account information at any time by contacting our customer support team. If you wish to ask that we erase your account information, please email us at firstname.lastname@example.org, but note that we may retain certain information as required by law or for legitimate business purposes.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights below for more information.
To prevent unauthorized access or disclosure, to maintain data accuracy, and to allow only the appropriate use of your Personal Data, we utilize industry standard physical, technical, and administrative controls and procedures to safeguard the information we collect. However, you should recognize there is always some risk involved in transmission of information over the internet or in a method of electronic storage.
Consent to Transfer
Retail Solutions’ Site and Platform are operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States or another destination outside of the European Economic Area (“EEA”), the United Kingdom, or your jurisdiction of residence. By using our Site or Platform, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States and in certain other countries where we may process your information, which you acknowledge have privacy and security laws that may not be as comprehensive or may be deemed inadequate when compared to the data protection standards in the country where you reside and/or are a citizen.
Changes to This Policy
We reserve the right to make non-material changes or updates to this Policy, or any policies or practices, at any time without notice to you.
If you have any questions or comments about this Policy, the practices or use of the Site or Platform, please feel free to contact us by email at email@example.com, or by mail to the following address:
8 Thornton Road, Oakland, NJ 07436, Attn: Privacy Office.
Your California Privacy Rights
Effective Date: January 1, 2020
I. Information We Collect
We have collected the following categories of information in the past 12 months:
|Category of Personal Information||Sources of Personal Information||How We Use this Personal Information||Categories of Third Parties we Share this Information with|
(including identifiers such as name, full shipping address, country of residence, phone number, username, password, and email address)
• Identity Verification Services
|To fulfill your orders, process your account registration, to communicate with you||Service providers
(including billing address, credit card information, banking information, telephone number and other information necessary to complete a transaction or purchase).
• Credit reporting agencies
|To process your payments||Service Providers|
(including record of products or services purchased, and the date and time the transaction occurred).
• Our payment & delivery services
|To process our orders and comply with our legal obligations||Service Providers|
(including marketing, product and service preferences)
|• Analytics providers
• Advertising networks
|To personalize the site or platform for you||Service Providers|
(including IP address, GPS, login data, browser, time zone, geographical location and any other unique identifier used to identify you or your device).
|• Analytics providers
• Advertising networks
|To personalize the site or platform for you||Service Providers|
|Social Security number
||• You||To establish a credit account and track available credit||Service Providers|
II. Disclosure of Personal Information
We disclose personal information to our service providers and Third Party Brands, as described above.
Retail Solutions does not and will not sell the personal information of consumers. In the preceding twelve (12) months, Retail Solutions, Inc. has not sold personal information.
III. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Access Your Information.
You have the right to request that Retail Solutions, Inc. disclose what personal information we have collected used or disclosed over the past 12 months.
Right to Request Deletion.
You have the right to request that Retail Solutions, Inc. delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Exercising Access and Deletion Rights.
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:
• Calling us at +1 833-508-3301, or
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
If you or an authorized agent submit a consumer request up to two times in a 12 month period at the toll-free number or website posted above, we will respond in accordance with the CCPA:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
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.
Right to Non-Discrimination.
We will not discriminate against you for exercising any of your CCPA rights.
IV. Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site or Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
V. Your EU and UK Privacy Rights
As detailed below, to the extent provided by the law of your jurisdiction, you may have legal rights in relation to the personal information about you that Retail Solutions holds. We may require you to verify your identity if you request this information.
Lawful basis for processing your personal data.
We process on the following legal bases:
1. Contract: It is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract.
2. Legitimate Interests: We process your personal data if it is based on our legitimate interests. For example, we may process personal data in reliance on a legitimate interest in the effective and lawful operation of our business, the effective delivery and improvement of our products, services, and platforms, information security operations, compliance with laws and regulations, compliance with requests for disclosure to law enforcement, courts, and regulatory bodies, and to prevent and detect fraud or suspected fraud. In relation to general inquiry and complaints you send us, our legitimate interest is to provide you with information you have requested and to provide customer support. You can object to the processing that we carry out on the grounds of legitimate interests. See the section “Rights of data subjects” below to find out how.
3. Consent: Where you have given us consent to do so, we provide you, or permit third parties to provide you, with information about goods or services which we feel may interest you. You have the right to withdraw your consent. Please see the section “Rights of data subjects” below to find out how.
4. Legal Claims: We need to process your personal data to defend or establish a legal claim (for example, claims relating to the sale of our goods and services under contract law).
Rights of data subjects
You have the following rights, where provided under applicable law, regarding your information (each of which are subject to various exceptions and limitations):
1. The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Policy.
2. The right of access: You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Policy). This is so you are aware and can check that we are using your information in accordance with data protection law.
3. The right to rectification: You are entitled to have your information corrected if it is inaccurate or incomplete.
4. The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services and platforms.
7. The right to object: You have the right to object to certain types of processing, in particular processing based on our legitimate interests. You also can object at any time to your information being used for direct marketing purposes (including profiling related to such direct marketing). Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
8. The right to refuse or withdraw consent: You have the right to refuse to provide and withdraw your consent to processing of your personal information at any time with effect for future processing.
If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Data Protection Commission in Ireland (DPC): https://forms.dataprotection.ie/contact
Please note your rights in relation to your personal data are not absolute. We may, for example, deny you access to your personal data when required or authorized by law, or if granting access would have an unreasonable impact on another individual’s privacy. We will retain and use your personal information as described in this Policy, including as necessary to comply with our legal and business obligations, resolve disputes, and enforce our agreements.
VI. Contact Information
If you have any questions or comments about this Notice, the ways in which Retail Solutions, Inc. collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: +1 833-508-3301
Retail Solutions, Inc.
8 Thornton Road
Oakland, New Jersey 07436