Website Policies / Disclaimers
Wireless Zone® Web Site Legal Notice & Disclaimers

Welcome to the Wireless Zone® Web Site. We hope that you will find our Web Site enjoyable and informative. Visit us often, but remember that your use of our Web Site is governed by the following terms and conditions of your use:

I. GENERAL

This Wireless Zone® Web Site is directed and intended for use only by persons ages 18 and older. Our Web Sites are not directed to, nor intended for use by, any child age 13 or under without prior parental consent provided to Wireless Zone®. Please see the Wireless Zone® Privacy Statement for further information.

II.Web Site CONTENT

The materials and information on this Web Site provided or posted directly by Wireless Zone®, including but not limited to all text, graphics, photographs, artwork, and the like (“Content”), as well as the trademarks, service marks and logos contained in our Content, are the intellectual property of Wireless Zone, LLC. and/or its affiliates or licensors (together, the “Wireless Zone Content”), protected by the Copyright and Trademark Laws of the United States and other jurisdictions.

Wireless Zone® Content posted to this Web Site, is provided to you for your information and personal use only, and may not be used, copied, reproduced, distributed, transmitted, broadcast, displayed, sold, licensed, or otherwise exploited for any other purposes whatsoever without the prior written consent of Wireless Zone, LLC.

Wireless Zone® is neither responsible nor liable for any Content posted to this Web Site by anyone other than Wireless Zone, LLC including without limitation, statements or opinions posted to discussion boards or forums, advertising, hyperlinks to other websites, and the like, and makes no representations with respect to the truth or appropriateness of any such third party Content.

III. PARTICIPATION IN INTERACTIVE ADVERTISEMENTS AND PROMOTIONS

Participation in interactive advertisements and promotions that may appear from time to time on the Wireless Zone® Web Sites is restricted to residents of the United States, ages 18 and older, and is subject to any and all further restrictions and limitations as Wireless Zone® shall impose from time to time with respect to participant eligibility for such interactive advertisements and promotions. If you do not meet the applicable eligibility requirements, you will be ineligible to participate or to receive any prizes or awards.

IV. HYPERLINKED WEB SITES

This Web Site contains “hyperlinks” to third party Web Sites to enable you to access those Web Sites directly from our Web Site. Wireless Zone® is neither responsible nor liable for the Content of any Web Site other than our own, and your use of such third party Web Sites is controlled by and subject to the Privacy Statements and Legal Notices of such third party Web Sites.

V. DISCLAIMERS

WIRELESS ZONE, LLC, ITS AFFILIATES, AND/OR ITS LICENSORS, PROVIDE THE CONTENT OF OUR WEB SITE AND THE WEB SITE ITSELF TO YOU SOLELY ON AN “AS IS” BASIS, AND DISCLAIMS ANY AND ALL WARRANTIES OR REPRESENTATIONS, EXPRESS OR IMPLIED, TO THE FULLEST EXTENT ALLOWED BY LAW WITH RESPECT TO THE WIRELESS ZONE® CONTENT AND OUR WEB SITE, INCLUDING BUT NOT LIMITED TO ANY AND ALL WARRANTIES AND REPRESENTATIONS OF TRUTH, ACCURACY, MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE OR ANY PURPOSE WHATSOEVER.

WIRELESS ZONE, LLC, ITS AFFILIATES, AND/OR ITS LICENSORS FURTHER DISCLAIM ANY AND ALL RESPONSIBILITY AND LIABILITY FOR (I) ERRORS, MISTAKES, OR INACCURACIES OF THE WIRELESS ZONE® CONTENT, (II) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO AND USE OF OUR WEB SITES, (III) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONAL INFORMATION AND/OR FINANCIAL INFORMATION STORED
THEREIN, (IV) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM OUR WEB SITES, (IV) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE WHICH MAY BE TRANSMITTED TO OR THROUGH OUR WEB SITES BY ANY THIRD PARTY.

WIRELESS ZONE, LLC, ITS AFFILIATES, FRANCHISEES AND/OR ITS LICENSORS SHALL IN NO EVENT BE LIABLE FOR ANY DIRECT, INDIRECT, CONSEQUENTIAL, SPECIAL, PUNITIVE, OR OTHER DAMAGES OF ANY NATURE WHATSOEVER, RESULTING FROM: (I) THE WIRELESS ZONE® CONTENT; (II) THIRD PARTY CONTENT THEREON, (III) YOUR USE OF, OR INABILITY TO USE, THE WIRELESS ZONE® WEB SITES, (III) YOUR PARTICIPATION IN ANY OF OUR INTERACTIVE ADVERTISEMENTS AND/OR PROMOTIONS, (IV) ANY PRODUCTS OR SERVICES PURCHASED FROM OUR WEB SITES OR (V)ANY THIRD PARTY WEB SITE HYPERLINKED TO OUR WEB SITES, WHETHER BASED IN TORT, CONTRACT, OR NEGLIGENCE, EVEN IF WE HAVE BEEN ADVISED OF SUCH ACTUAL OR POTENTIAL DAMAGES. YOUR ONLY REMEDY SHALL BE TO CEASE ANY FURTHER USE OF OUR CONTENT OR WEB SITES.

VI. OUR RIGHTS

Wireless Zone, LLC reserves the right, on behalf of itself, its affiliates, and its licensors, to take any and all action necessary, and to seek any and all remedies available to us to prevent the unauthorized use of our Content and/or our Web site, including but not limited to the right to take appropriate legal action, to seek injunctive relief and/or monetary damages, and to prevent further use of our Web site by anyone who infringes our intellectual property rights or otherwise misuses our Content or Web site in any way.

You agree to indemnify and hold harmless Wireless Zone, LLC, its affiliates, franchisees and/or its licensors, from any and all damages, costs, or expenses, including reasonable attorneys fees and court costs, for any action brought against Wireless Zone, LLC, its affiliates, franchisees and/or its licensors (i) by a third party as a result of your access to and/or use of this Web Site and/or (ii) if Wireless Zone, LLC, its affiliates, franchisees and/or its licensors is the prevailing party in any action brought by you to enforce this Legal Notice against us.

Wireless Zone, LLC reserves the right to amend or change any or all of the terms and conditions of this Legal Notice by posting any such amendments or changes to this Legal Notice. Such amendments and changes shall be effective as of the date of posting to this Web Site.

VII. GOVERNING LAW AND JURISDICTION

You acknowledge and agree that any disputes between you and Wireless Zone, LLC, its affiliates, franchisees and/or its licensees arising out of your access to and/or use of our Content, our Web Site, this Legal Notice, and/or our Privacy Statement, shall be governed by the laws of the state of Connecticut as if entered into solely by residents thereof, without regard to its conflicts of laws provisions, and any action taken by either of us against the other shall be brought in a court of appropriate jurisdiction in Hartford County, Connecticut, and you expressly agree to venue and personal and subject matter jurisdiction in such court.

VIII. CONTACTING

If you have any questions about this Legal Notice, this Web Site, Wireless Zone®, or if you would like further information about Wireless Zone, LLC you can contact our corporate headquarters:

Wireless Zone, LLC
795 Brook Street, #5
Rocky Hill, Connecticut 06067
Phone: 860-632-9494
Fax: 860-613-0041

 


Wireless Zone® Web Site Privacy Policy

Purpose

The Wireless Zone® system is operated by Wireless Zone, LLC, which does business under the name Wireless Zone® and other trade names and trademarks, and which operates through independently owned, franchised retail locations (the “Wireless Zone System”). Wireless Zone, LLC and its telecommunications carrier(s), independent franchisees and affiliates are called the “Wireless Zone Group,” and are sometimes referred to using the words “we,” “us,” or “our.” The purpose of this statement is to inform you of the types of information the Wireless Zone Group obtains about visitors to our website, how the information is obtained, how it is used, how long it is retained and how you can restrict its use or disclosure.

Website Legal Notice and Disclaimers
Your use of our website is governed by the Legal Notice and Disclaimers.  You should read the Legal Notice and Disclaimers carefully before using the website.

What information do we collect?

Information You Give Us
We receive and may store any information you enter on our website or give to our website in any other way. For example, we collect information you provide when you place an order, complete a franchise application, apply for a job, enter a contest, or register to receive news, announcements or other materials. This information may include personal information such as:

– Your name
– Your mailing address
– Your e-mail address
– Your phone number
– Your social security number
– Your credit card number

This information may include any other personal or preference information you provide to us. Some of this information may be processed or used as demographic information, such as your Zip Code, age bracket, income level, education level, etc. The information may also include information you submit about other people, for example, the name and address of a gift recipient.

Financial Information
We only request financial information, such as credit card numbers, financial references, credit references, credit information, and similar information, from you if you wish to purchase products or services through our website, or if you are applying to become a Wireless Zone® franchisee.

Information from Other Sources
We may receive information about you from other sources. This may help improve the personalization of our service to you by providing better product recommendations or special offers that we think will interest you.

Automatic Information
We receive and store certain types of information whenever you interact with our website, such as your IP address or domain name. We use “cookies” like many other websites. Through “cookies” we obtain certain types of information when your web browser accesses our website. There are utilities designed to help you visit websites anonymously. Although we cannot provide you with a personalized experience or certain services at our website if we cannot recognize you, we want you to be aware that these tools exist.

What are “Cookies” and how do we use them?

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser. Your web browser stores the information on your hard drive and when you return to that website later, the cookie is transmitted back to the server that originally sent it to you. Cookies provide a way for a server to recall a previous request or previous registration, or to keep track of a transaction as it progresses, so that information does not have to be repeated. To be notified when you are about to receive a cookie, you can configure your browser to alert you when a website is attempting to send you a cookie and at that time you will have the option of refusing the cookie. You can check your hard drive for cookie files, on the “cookies.txt” file on your PC’s hard drive; or under “magic cookies” on a Macintosh.

Does our website share information it receives?

The Wireless Zone Group
We share information we collect at our website within the Wireless Zone Group. Persons and entities within the Wireless Zone Group may use this information to offer you products and services that may be of interest to you.

Selected Organizations
We may share information with carefully selected telecommunications services carriers and providers, vendors, business partners and other organizations, which are not within the Wireless Zone Group. These companies and organizations may use the information we share to provide special opportunities and offers to you.

Service Providers
Our website may also share information with companies that provide support services to us (such as a printer, mailing house or web host) or that help us market our products and services. These companies may need information about you in order to perform their functions. These companies are not authorized to use the information we share with them for any other purpose.

Protection of Our Website, and Others
We may disclose information you provide to our website when we believe that disclosure is appropriate to comply with the law; to enforce or apply the terms and conditions, this policy, and other agreements; or to protect the rights, property or safety of our website, our users and visitors, or others.

Business Transfers
If some or all of the business assets of our website are sold or transferred, we generally would transfer the corresponding information regarding our visitors. We also may retain a copy of that visitor information.

What choices do I have?

E–Mails
If you provide our website with your e-mail address, you may receive e-mails from us. If you do not want to receive marketing or promotional e-mails from us, please click here to send your request. 

You may receive e-mails from other members of the Wireless Zone Group or vendors, business partners and other organizations, if they received your e-mail address from other sources or as a result of their transactions or experiences with you.

Sharing with Other Companies
If you do not want us to share information you provide to our website with vendors, business partners and other organizations that are not part of the Wireless Zone Group, please send your request to Wireless Zone, LLC.

Obtaining a Copy of Your Personal Information
If you wish to obtain a copy of your personal information that you provided to our website, please send your request to Wireless Zone, LLC.

Links to and from other websites

Our website may offer links to other sites. Other sites may have their own policies regarding privacy. If you visit one of these sites, you may want to review the privacy policy on that site. In addition, you may have linked to our website through another site. In such cases the site you linked from may collect information from people who click on the banner or link. You may want to refer to the privacy policies on those sites to see how they collect and use this information.

Children

We recognize the particular importance of protecting privacy where children are involved. We are committed to protecting children’s privacy on the Internet and we comply fully with the Children’s Online Privacy Protection Act. We do not knowingly collect personally identifiable information from children under the age of 13. If a child has provided our website with personally identifiable information, we ask that a parent or guardian call 860-632-9494 extension 8271 or contact us by email and we will delete the information about the child from our files.

Our Commitment to Data Security

We have appropriate physical, electronic, and procedural security safeguards to protect and secure the information we collect.

In order to maintain the authenticity and confidentiality of the information you provide online to the Wireless Zone Group, including the Wireless Zone Group’s online purchase order forms, the Wireless Zone Group utilizes secure server technology which uses a secure socket layer (SSL) protocol to secure a connection between your browser and the Wireless Zone Group’s Web server. The SSL protocol protects the integrity of your correspondence with the Wireless Zone Group by providing three major security capabilities:

The information send between your browser and our Web server is encrypted so an unauthorized third party may not read the contents of the message.

While SSL is active, you can view the identity and owner of the Web server your browser is connected to by clicking on the closed padlock. This information is contained in a digital certificate issued by a public certificate authority and exchanged with your browser when the SSL connection is established.

SSL provides a mechanism which verifies that the data has not been tampered with between the time the sender sent it and the receiver received it.

There may be a slight change in the appearance of your browser when you enter the online purchase order forms. This change may vary depending on the type and version of the browser you use. While the SSL connection is active, you will see a note at the bottom of each page indicating a secure connection is active. You will also see a closed padlock at the lower left or right corner of your browser (depending on which browser you are using).

Disclaimer; Limitation

The Wireless Zone Group’s website and the content contained herein are provided “as is.” The Wireless Zone Group makes no representations or warranties of any kind whatsoever in connection with its websites. Further, the Wireless Zone Group disclaims any express or implied warranties including, but not limited to, non-infringement, merchantability and fitness for a particular purpose. The Wireless Zone Group does not warrant and represent that its websites will be error free or not interrupted from time to time. To the extent permitted by law, the Wireless Zone Group shall not be liable for any direct, indirect, consequential, incidental or special damages arising from or in connection with the Wireless Zone Group’s websites and the use thereof. In no event shall the Wireless Zone Group’s liability to you or any third-party for damages, losses and/or any cause of action exceed $100.00.

Trademarks

This website contains Wireless Zone Group and third-party trademarks and service marks. All marks are the property of their respective companies. All rights in the intellectual property contained in this website including copyright, trademarks, trade secret and patent rights are reserved. Access to this website does not constitute a right to copy or use any of the intellectual property of the Wireless Zone Group or their respective affiliates and suppliers. Statutory notice contained herein represents trademark status in the United States.

Copyrights

All materials contained on this website are subject to the ownership rights of Wireless Zone, LLC,  Wireless Zone Group companies and/or third parties. No permission is granted to you to print, copy, reproduce, distribute, transmit, upload, download, store, display in public, alter, or modify the content contained on this website.

Your Consent

By using our website, you consent to our use of information that is collected or submitted as described in this online privacy policy. We may change or add to this privacy policy so we encourage you to review it periodically.

Questions about this Policy

If you have questions or comments about this policy, this Web Site, Wireless Zone®, or if you would like further information about Wireless Zone, LLC you can contact our corporate headquarters:

Wireless Zone, LLC
795 Brook Street, #5
Rocky Hill, Connecticut 06067
Phone: 860-632-9494
Fax: 860-613-0041

 


Wireless Zone® Data Protection and Privacy Policy

Introduction

Welcome to the Round Room Holdings, Inc. Privacy Policy.

Round Room Holdings, Inc., together with its subsidiaries, affiliates, agents, vendors, and licensees (collectively, “Round Room,” “us,” “we,” or “our“) respects your privacy, and takes the responsibility of protecting the personal information that you provide to us either via (1) our websites [http://www.roundroom.com; https://www.redux.com; http://www.tccrocks.com; http://www.tccgives.com; http://www.cultureofgood.com; http://www.wirelesszone.com] (or any other website on which we place this Privacy Policy, referred to herein collectively as the “Website“); (2) pursuant to a Membership Enrollment Form (a “Membership Agreement“); or (3) to one of our service partners (each a “Partner“), very seriously. This Privacy Policy describes how we collect, use, and disclose information we receive from users of the Website, our Partners, and persons who are a party to any Membership Agreement, including users in California, Canada, and the European Economic Area (“EEA”) (collectively, “you” or “users”). For the purposes of compliance with the California Consumer Privacy Act (“CCPA”), the EU General Data Protection Regulation (“GDPR”) and the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”), we are the “controller” of “personal data” or “personal information” (defined below) that we receive from you hereunder. Users may be referred to as Data Subjects in the Privacy Policy. A “Data Subject” means an identified or identifiable natural person as set forth in the GDPR or PIPEDA.

We have adopted this Privacy Policy to explain (1) what information may be collected when you access the Website, use any of our mobile or other applications (the “Applications“), access or use any of our social media pages, execute a Membership Agreement; or provide information to us through any Partner; (2) how we and others use this information; (3) under what circumstances we may disclose the information to third parties; and (4) the instances in which we may allow third parties to collect information directly. Depending on your activities when using or accessing our Website, Applications, or social media pages, or submitted to us through execution of the Membership Agreement, or any information supplied or collected by us or any Partner pursuant to providing services under the Membership Agreement (collectively, the “Services“), you may from time-to-time be required to agree to additional terms and conditions. Without limiting the foregoing, our Services include any promotion, contest, or sweepstakes which refers to this Privacy Policy with respect to the collection and use of your information.

This Privacy Policy applies regardless of whether you use our Services via a computer, mobile device, or any other platform or equipment owned by you, us or any Partner (collectively, the “Equipment“). This Privacy Policy also applies only to information we collect through our Services, including, without limitation, our Website, Applications, and social media pages, and does not apply to our collection of information from other sources.

Modifications to this Privacy Policy

We generally keep this Privacy Policy posted on our Website and accessible in our Applications. You should review this Privacy Policy frequently, as it may change from time to time without notice. Any changes will be effective immediately upon the posting of the revised Privacy Policy. WHEN YOU USE OUR SERVICES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP USING OUR SERVICES. Please note, however, that if we decide to use your personal data in a manner materially different than what is provided in this Privacy Policy or what we advised at the time it was collected, we will notify you of this change by email to the last email address provided to us or through our Applications. You will have a choice (by means of an “opt-out” opportunity) as to whether or not we use your information in this different manner. If you opt out, we will use your personal data in accordance with the terms in place when the information was collected.

INFORMATION WE COLLECT

We typically collect four kinds of information about you when you use our Services:

  1. Personal Data: Our definition of personal data includes any information that may be used to specifically identify or contact you, such as your name, address, or phone number. Personal data also includes information that may be used to identify you indirectly, including by reference to an online identifier, location data, or services identification number. As a general policy, we do not automatically collect your personal data when you visit our Website. In certain circumstances, we may request, allow, or otherwise provide you an opportunity to submit your personal data in connection with a feature, program, promotion, or some other aspect of our Services. For instance, you may: (a) provide your name, mail/shipping address, email address, credit card number, and phone number when registering with our Services and executing a Membership Agreement; (b) provide certain demographic information about yourself (e.g., age, gender, purchase preference, usage frequency) when using our Services; or (c) post a general comment and/or recommendation on our Services. Certain information may not be personal data when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and name). Whether or not you provide this information is your choice; in many instances, however, this type of information is required to enter into a Membership Agreement or participate in a particular activity, realize a benefit we may offer, or gain access to certain content or features available through our Services.
  2. Usage Data: Our definition of usage data is any information that does not personally identify you (also referred to herein as “non-personal data“) that is automatically collected anytime you visit the Website, including information such as browser type and referring websites. Usage data can include certain personal data that has been de-identified; that is, information that has been rendered anonymous. We obtain usage information about you from information that you provide us, either separately or together with your personal data. We also automatically collect certain usage data from you when you access our Services with your Equipment. This information can include, among other things, your wireless carrier, your IP addresses, the type of browser you are using (e.g., Internet Explorer, Firefox, Safari, Opera), the operating system you are using (e.g., Vista, Windows XP, Mac OS, Android, iPhone) on the Equipment, the domain name of your Internet service provider (e.g., CenturyLink, Google, Cox, AOL), the search terms you use on our Services, the specific web pages you visit, how much you use our Services, and the duration of your visits.
  3. Financial Data: Our definition of financial data is any information needed to facilitate the purchase of items or services, including credit card information. Financial data may constitute personal data, depending on the circumstances of its collection and use.
  4. Wireless Carrier and Service Information. Our definition of wireless carrier and service information is any information collected by us or any Partner pursuant to provision of any Services which includes, but is not limited to, the make and model of any Eligible Device (as defined below), serial number of any Eligible Device, and location of a wireless retailer servicer. “Eligible Device” hereunder means any smartphone, tablet, or mobile broadband device identified by you in any Membership Agreement.

HOW WE USE & DISCLOSE THE INFORMATION COLLECTED

  1. Personal Data: The personal data you voluntarily submit to us is generally used to provide services pursuant to the Membership Agreement, carry out your requests, respond to your inquiries, better serve you, or in other ways naturally associated with the circumstances in which you provided the information. We may also use this information to later contact you for a variety of reasons, such as customer service, providing you promotional information for our products or those of any Partner, our parent company, subsidiaries, or other affiliated companies (“affiliated companies“), or to communicate with you about content or other information you have posted or shared with us via use of our Services.

    You may opt-out from receiving future promotional information from us or our affiliated companies, or direct that we not share your information with any affiliated companies, as set forth below.

    In certain instances, we may also share your personal data with third parties performing functions on our behalf (or on behalf of our affiliated companies) or accessing the Services (e.g., vendors that process credit card orders, provide our Services, administer our promotions, provide us marketing or promotional assistance, analyze our data, assist us with customer service). These third parties agree to use this information, and we share information with them, only to carry out our requests or provide Services.

    In addition, we may share your personal data with third parties who assist us in using the content or other information you have posted or shared with us via our Services (e.g., production companies we may use). Further, we may share your personal data with third parties such as our co-promotional partners and others with whom we have marketing or other relationships. Except as provided in this Privacy Policy, the Membership Agreement, any terms of use of any of the Services, or as set forth when you submit the information, your personal data will not be shared or sold to any third parties without your prior approval.

  2. Usage Data: We use usage information in a variety of ways. For example, we may use usage information to evaluate use of our Services (e.g., visits to our Website, use of our Applications), analyze site traffic, track purchases, understand customer needs and trends, carry out targeted promotional activities, and to improve our Services. We may use your usage information by itself or aggregate it with information we have obtained from others. We may, among other things, share your usage information with any Partner, our affiliated companies, allow third parties to collect such information directly from you.
  3. Wireless Carrier and Service Information: We use, and our Partners use, wireless carrier and service information in order to provide services pursuant to the Membership Agreement.
  4. General Uses and Disclosures: We use and share the information, including personal data, we collect from users for the purposes described below. To perform the following tasks, we may transfer your data to countries outside the United States and EEA using appropriate safeguards when necessary. When necessary, we will obtain your consent before using your data for these purposes:
    – Provision of Services to Website Users. If you use the Website, we will use your information to process and respond to your requests, comments, inquiries, and other forms you submit through the Website.
    – Processing Online Purchases. We use your Financial Data to process any purchases made on the Website, including disclosure of your Financial Data to third-party payment processors.
    – Improving our Services. We use your information to enhance our understanding of our users’ preferences and optimize the performance of the Services.
    – Disclosures to Service Providers. We share your information with third-party service providers that assist us with hosting and maintaining the Website, processing credit card information, analyzing online activity on the Website, marketing our services, and managing our daily business operations and delivery of the Services. We share only the minimum amount of personal data with these service providers that they need to perform their tasks. We also enter into contracts with these service providers that require them to protect personal data.
    – Compliance with Legal Obligations. We will share your information with law enforcement, government officials, regulatory agencies, or other parties when we are required to do so by applicable law. We will also disclose your information to comply with a judicial proceeding, court order, subpoena, or legal process.
    – Other Legitimate Interests. We will use and disclose your information when necessary for our legitimate interests, as long as such interests are not overridden by our users’ interests, rights, and freedoms with respect to their personal data.
  5. Legal Bases for Processing: The legal bases for processing your personal data for the purposes described above or elsewhere in this Privacy Policy, including in Section C below, are, without limitation, that (1) it is necessary to perform a contract with you, including without limitation the Membership Agreement or in order to take steps at your request prior to entering into a contract; (2) it is necessary to comply with a legal obligation (such as notifying you of Privacy Policy changes); and/or (3) it is necessary for the pursuit of our legitimate interests or those of a third-party.

CCPA Notice of Collecting and Sharing Personal Information

The chart below lists the categories of Personal Information we have collected, the sources from which we have collected Personal Information, and our purposes for sharing Personal Information, within the last twelve (12) months:

C. COOKIES AND PREFERENCE-BASED ADVERTISING

  1. Cookies and Web Beacons: We automatically receive and store certain types of usage data whenever you interact with us. For example, like many websites, we use “cookies” and “web beacons” (also called “clear gifs” or “pixel tags”) and embedded scripts to obtain certain types of information when you use or access our Services. Cookies are small files that we transfer to your computer’s hard drive or your web browser memory to enable our systems to recognize your browser and to provide convenience and other features to you. Cookies and other user tracking mechanisms (e.g., local shared objects), by themselves, do not tell us your email address or other personal data unless you choose to provide this information to us by, for example, registering at the Website or providing information via any Membership Enrollment Form. However, once you choose to furnish us with personal data, this information may be linked to the data stored in the cookie or other tracking mechanisms. We may use cookies and other user tracking mechanisms, including “persistent cookies”, which will remain on your computer even after you close your browser, to understand website usage and to improve the content and offerings on the Website. For example, we may use cookies to personalize your experience at the Website and to save your password in password-protected areas. We also may use cookies to offer you products, programs, or services. While most browsers are set to accept cookies and other tracking devices by default, you can set yours to refuse tracking devices or to alert you before accepting them. However, by disabling tracking devices, you may not have access to the entire set of features of the Website. Your browser manufacturer has information on changing the default setting for your specific browser.

    Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, when an email has been opened, and to provide other information. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. We may use web beacons to improve your experience with the Website, including to provide you with content customized to your interests and to understand whether users read email messages and click on links contained within those messages so that the Website can deliver relevant content. Our web beacons may collect some contact information (for example, the email address associated with an email message that contains a web beacon).

    Other examples of the information we collect and analyze in this manner include: the Internet Protocol (IP) address used to connect your Equipment to the Internet; computer and connection information such as browser type and version, operating system, and platform; your activities on our Website, including the products you view or searched for, as well as the URL you come from and go to next (whether this URL is on our Website or not); and cookie number. It is important to note that the cookies and Web beacons that we use do not contain and are not tied to personal data or personally identifiable information about you.

    If you are concerned about the storage and use of cookies, you may block or limit the storage of cookies via browser controls or other software (we do not make any promise that our Services will recognize or be able to work with any such browser controls/software – see below for Do Not Track options). You may also be able to delete cookies manually from your Equipment through your internet browser, operating system, or other programs. Please note, however, that some portions of our Services will not function properly or be available if you are able and do block and/or delete cookies.
  2. Preference-Based Advertising: We may work with third parties, including advertising companies and website analysis firms, who use cookies and web beacons to collect usage data when you use our Services, including without limitation our Website and third-party sites. This usage data, collected through cookies and web beacons, is typically used by these third-party advertising companies (i.e., advertising networks) to serve you with advertisements while on third-party sites tailored to meet your preferences and needs. If you do not wish to participate in this activity, go to www.aboutads.info and follow the simple opt-out process.

    A couple of important notes about this opt-out tool: (1) it includes all the advertising networks that we may work with, but also many that we do not work with; and (2) it may rely on cookies to ensure that a given advertising network does not collect information about you (“Opt-out Cookies”) – an explanation of how Opt-out Cookies work can be found on www.aboutads.info. Therefore, if you use different Equipment, change web browsers, or delete these Opt-out Cookies from your computer, you will need to perform the opt-out task again.
  3. Do Not Track Features: Certain browsers may offer you the option of providing notice to websites that you do not wish for your online activities to be tracked for preference-based advertising purposes (“DNT Notice”). Some browsers are, by default, set to provide a DNT Notice, whether or not that reflects your preference. Providing DNT Notice is often touted as a means to ensure that cookies, web beacons, and similar technology are not used for preference-based advertising purposes – that is, to restrict the collection of non-personally identifiable information about your online activities for advertising purposes. Unfortunately, given how preference-based advertising works, DNT Notices may not effectively accomplish this goal. For this and a variety of other reasons, with respect to our Website, we do not take any action based on browser based DNT Notices. Rather, if you do not wish to participate in preference-based advertising activities, you should follow the simple opt-out process identified below.

D. OTHER USES & INFORMATION

  1. IP Addresses: An IP address is a number that is automatically assigned to the Equipment whenever you access the Internet. Web servers (computers that serve up web pages) automatically identify the Equipment by its IP address. When visitors request pages from our Website, our servers typically log their IP addresses. We collect IP addresses for purposes of system administration, to report non-personal aggregate information to others, and to track the use of our Services. IP addresses are considered non-personally identifiable information and may also be shared as provided above. It is not our practice to link IP addresses to anything personally identifiable; that is, the visitors’ session will be logged, but the visitor remains anonymous to us.
  2. Email Communications: If you send us an email with questions or comments, we may use your personal data to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. We may send you emails for a variety of reasons –such as emails in response to your request for a particular service or your registration for a feature that involves email communications, that relate to purchases you have made with us (e.g., product updates, customer support), about our other products, services, or events, or when you consent to being contacted by email for a particular purpose. In certain instances, we may provide you with the option to set your preferences for receiving email communications from us – that is, agree to some communications but not others. You may “opt-out” of receiving future commercial emails from us by clicking the “unsubscribe,” “opt-out,” or similar link included at the bottom of most emails we send, or as provided below; we reserve the right, however, to send you transactional emails such as customer service communications.
  3. Transfer of Assets: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the personal data and non-personal data we have about you will be transferred to and used by this acquiring entity, though we will take reasonable steps to ensure that your preferences are followed. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
  4. Other: Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any personal data or non-personal data about you if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property of our Services, or other users; or (d) in an emergency to protect the health and safety of our customers or the general public.

E. CHILDREN

The features, programs, promotions, and other aspects of our Services requiring the submission of personally identifiable information are not intended for children. We do not market and do not knowingly collect personally identifiable information from children under the age of 13. Certain benefits of our Services may be restricted to adults, age 18 or older. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us, please contact us as provided in Section H below. A parent or guardian of a child under the age of 13 may review and request deletion of such child’s personally identifiable information as well as prohibit the use thereof. If we discover that we have inadvertently collected information from a child under 13 years of age, we will promptly take all reasonable measures to delete such information from our systems.

F. KEEPING YOUR INFORMATION SECURE

We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse, and alteration of the information under our control. Please be advised, however, that while we strive to protect your personal data and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online or through our Services, and are not responsible for the theft, destruction, or inadvertent disclosure of your personal data. In the unfortunate event that your “personal data” (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by email (at our sole and absolute discretion) to the last email address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.

G. OTHER SITES/THIRD-PARTY LINKS

Our Services may link to or contain links to third-party websites, including the websites of our Partners, that we do not control or maintain, such as in connection with purchasing products we may recommend or reference via our Services and/or advertisements you may see while using our Services. We are not responsible for the privacy practices employed by any third-party website. We encourage you to note when you leave our Website and to read the privacy statements of all third-party websites before submitting any personally identifiable information.

H. CONTACT & OPT-OUT INFORMATION

You may contact us as provided below if: (a) you have questions or comments about our Privacy Policy; (b) wish to make corrections to any personally identifiable information you have provided; (c) want to opt-out from receiving future commercial correspondence, including emails, from us or our affiliated companies; or (d) wish to withdraw your consent to sharing your personally identifiable information with others.

Email:   compliance@roundroom.com

Mail:     
ATTN: Compliance Officer
Round Room
525 Congressional Blvd
Carmel, IN  46032

We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Services.

I. SOLE STATEMENT

This Privacy Policy as posted on this Website is the sole statement of our privacy policy with respect to our Services, and no summary, modification, restatement or other version thereof, or other privacy statement or policy, in any form, is valid unless we post a new or revised policy to the Website.

J. YOUR RIGHTS

Data Subjects from the EEA have the following rights under the GDPR:

  • To access the Personal Data we maintain about you;
  • To be provided with information about how we process your Personal Data;
  • To correct your Personal Data;
  • To have your Personal Data erased;
  • To object to or restrict how we process your Personal Data; and
  • To request your Personal Data to be transferred to a third-party.

Data Subjects from Canada have the following rights under PIPEDA:

  • To know why an organization collects, uses or discloses your personal information;
  • To expect an organization to collect, use or disclose your personal information reasonably and appropriately, and not use the information for any purpose other than that to which you have consented;
  • To know who in the organization is responsible for protecting your personal information;
  • To expect an organization to protect your personal information by taking appropriate security measures;
  • To expect the personal information an organization holds about you to be accurate, complete and up-to-date;
  • To obtain access to your personal information and ask for corrections if necessary;
  • To complain about how an organization handles your personal information if you feel your privacy rights have not been respected; and
  • To receive products or services even if you refuse consent for the collection, use or disclosure of your personal information, unless that information is essential to the transaction.

To exercise the above rights, please contact us at the information provided above. We will consider and process your request within a reasonable period of time. Please be aware that under certain circumstances, the GDPR or PIPEDA may limit your exercise of these rights.

Consumers from California (California residents) have the following rights under the CCPA:

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your request and confirm your identity, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Currently, we do not provide a right to know for business-to-business (B2B) personal information.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our Partners 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, fulfill the terms of a Membership Agreement, 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.
  • 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 in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • 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.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our Partners to take similar action.

Currently, we do not provide these deletion rights for B2B personal information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

  • Calling us at 855-799-8301
  • Emailing us at: compliance@roundroom.com
  • Mailing a request to:
    ATTN: Compliance Officer
    Round Room
    10300 Kincade Dr.
    Fishers, IN 46037

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may make a request to know twice within a 12-month period. Your request to know or delete must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Additionally, you must 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 the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at compliance@roundroom.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

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 our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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.

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.

K. RETENTION OF PERSONAL DATA

For Data Subjects from the EEA and Canada, we will retain your Personal Data only as long as necessary to process your request or other submission, fulfill the terms of our service contract with you, and comply with applicable law.

L. HOW TO WITHDRAW CONSENT

At any time, Data Subjects from the EEA or Canada may withdraw consent you have provided to us for using, disclosing, or otherwise processing your Personal Data. You may withdraw your consent by contacting us pursuant to Section H above.

Please note that your withdrawal of consent to process certain Personal Data about you (1) may limit our ability to deliver services to you and (2) does not affect the lawfulness of our processing activities based on your consent before its withdrawal.

M.  HOW TO FILE A COMPLAINT

You may file a complaint regarding the Privacy Policy or our privacy practices by contacting us at the information we provide below. Additionally, Data Subjects from the EEA may file a complaint with EU data protection authorities (DPAs). A list of DPAs from the European Commission may be found here: http://ec.europa.eu/newsroom/article29/document.cfm?action=display&doc_id=50061.

Data Subjects from Canada may file a complaint with the Office of the Privacy Commissioner of Canada. Additional information can be found here: https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/.

You may also contact us using the contact information provided above to be directed to the appropriate DPA contact(s).