Effective Date: June 17, 2021
This Privacy Policy is being provided to you by RWS of America, LLC, RWS Home Service Contracts, LLC, and Residential Warranty Home Protection of California, Inc. (individually and collectively “RWS”, “we” or “us”) on behalf of itself and certain of its affiliates and subsidiaries. This Privacy Policy applies to information we receive from or about you, including personally identifiable information, in connection with your access or use of: (a) the websites https://residentialwarrantyservices.com, https://homewarrantycalifornia.net, https://rwshomeservicecontracts.com (together with any successor website, the “Site”), (b) other interactive properties, including, but not limited to, any mobile applications enabling you to access the Site (together with the Site, the “RWS Applications”), (c) the products and services provided by RWS, including through the RWS Applications or offline (the “Product(s)” and “Service(s)”), (d) offline communications with RWS, including direct mail, telephone and postal mail and (e) any other means or applications in which you connect with RWS or a third party from whom RWS receives information about you.
By accessing or using the RWS Applications or our Products and Services, registering with, providing personal information to, or communicating with, RWS, you explicitly accept, without limitation or qualification, the collection, use, storage, and transfer (including international transfer) of your personal information in the manner described in this Privacy Policy. THIS PRIVACY POLICY AFFECTS YOUR RIGHTS AND LIABILITIES UNDER THE LAW. If you do not agree to the terms of this Privacy Policy, do not access, or use the RWS Applications, provide us with personal information or otherwise communicate with us.
INFORMATION WE COLLECT
We may collect different types of information about you, depending upon how you interact with us. This information may include personal information, Financial Information, demographic information, log-in information and Device information. Sometimes we collect combinations of all these types of information or aggregate some or all of these types of information to improve the Products and Services and facilitate other legitimate business purposes. In each case, when using the RWS Applications, it is indicated on the RWS Applications whether any personal information or demographic data must be provided for you to access and use the RWS Applications or purchase the requested Product or Service.
Connecting with the RWS Applications and Information Provided by You
When You Register or Otherwise Contact Us. When you provide us with information (including personal information) in connection with a particular activity, you agree that such action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to receiving communications from RWS (and its affiliates and subsidiaries) through the information you provided to us. You also attest that you have the legal authority over any telephone number you provide to us and can provide the authorization to contact you. This means RWS may contact you, in person or by recorded message, by e-mail, telephone or mobile telephone number (including use of automated dialing equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving.
Registration Information. We will collect personal information from you if you register on the RWS Applications or place an order for our Products or Services, which may include, but is not limited to, name, address, phone number(s), and email address(es). You may not use a user/account name that is vulgar or otherwise offensive (as determined by RWS), infringes any trademark or other proprietary rights of others, or is used in any way that violates the terms of use of the Site (the “Terms of Use”). RWS reserves the right to deny, in its sole discretion, any user access to the RWS Applications or our Products and Services without notice, for any or no reason.
Financial Information. Financial information is information that you provide to us, including your bank account number, routing number, debit or credit card number and related billing information (collectively, the “Financial Information”). We require such Financial Information in order to process payment for the purchase of a Product or Service that you have requested. By submitting your Financial Information, you consent to our providing your Financial Information to those Authorized Third Party Service Providers as are reasonably necessary to support and process your transactions as well as your credit card issuer and banking institution. We ask that you do not enter Financial Information into your profile, except in the fields provided for that information.
Facebook. You may be given the option to link your Facebook account so that you can comment on the RWS Applications and your interaction with RWS or take advantage of other features of the RWS Applications. When you comment on the RWS Applications using your Facebook username and password and click “allow” on the Facebook permission authorization screen, we will automatically import all information that you allow to be imported from your Facebook profile based upon your privacy settings at Facebook, such as your location, your interests, etc. (collectively, “Permitted Facebook Profile Content”) and you give us permission to: (a) capture, store, use and display your Permitted Facebook Profile Content, including syncing access to such Permitted Facebook Profile Content when you are not using RWS Applications and (b) otherwise use Permitted Facebook Profile Content as described in this Privacy Policy. The authentication of your Facebook login credentials is conducted solely through Facebook.
User Generated Content. The RWS Applications may contain review or chat areas or other message, communication or other mechanisms designed to enable you to communicate with others or to post content on the RWS Applications (the “Communication Services”). Please remember that any information you disclose while participating with the Communication Services becomes public information, becomes the property of, and is subject to redistribution by, RWS. You should exercise caution and discretion when deciding to disclose your personal information in a submission or posting. There is no expectation of privacy when posting or otherwise participating on the Communication Services. If you post content, such as messages, reviews, or photos, please be aware that any personally identifiable information contained in such content is accessible to registered users or visitors to that RWS Application or Communication Services and we have no control over how those users may use your personally identifiable information. We have the right, but not the obligation, to monitor any activity and content associated with the Communication Services. We reserve the right to take action in connection with any content, including that which we deem inappropriate. Please review our Terms of Use for more information regarding your appropriate use of these Communication Services.
Information Collected Through Technology
In addition to any personal information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs to track and record certain information. As you use our RWS Applications, your browser and devices communicate with servers operated by us, our business partners and our service providers to coordinate and record your activity and fulfill your requests (“Usage Information”). We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access our RWS Applications, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. In addition, we collect your IP address or other unique identifier (“Device Identifier”) from your computer (or other device) used to access the RWS Applications (each, a “Device”). A Device Identifier is a number that is automatically assigned to the Device used to access the RWS Applications, and our computers identify your Device by its Device Identifier. We may also collect information about the website you were visiting before you came to our RWS Applications and the website you visit after you leave our RWS Applications if this information is supplied to us by your browser. We may use this Usage Information for a variety of purposes, including to enhance or otherwise improve the RWS Applications.
The information from cookies and related technology is stored in web server logs and also in web cookies kept on your Device(s), which are then transmitted back to our Site by your Device(s). These servers are operated, and the cookies managed, by us, our business partners or our service providers. For example, when you visit RWS Applications, we and our service providers may place cookies on your Device(s). Cookies allow us to recognize you when you return to an RWS Application and may track and target your interests in order to provide a customized experience. Cookies also help us detect certain kinds of fraud. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the RWS Applications. Some cookies contain serial numbers that allow us to connect your activity with RWS Applications with other information we store about you in your profile or as related to your interactions with RWS Applications.
Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases Session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use Persistent cookies for a number of purposes, such as retrieving certain information you have previously provided. “Flash” cookies, known as local shared objects, are data files placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device to personalize your visit. Our third-party service providers also may use Flash cookies to collect and store information. Flash cookies are different from standard browser cookies because of the amount of, type of, and way data is stored. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. You can choose to have your computer warn you each time a Persistent or Session cookie is being sent, or you can choose to turn off such cookies through your browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. However, cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies, click www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. In some cases, you may be able to disable cookies on your Device. However, if you choose to disable cookies on your Device, some features of the RWS Applications may not function properly. For instance, if cookies are disabled, you will not be able to log into the Site and therefore you will experience an anonymous user experience.
Pixel tags and web beacons are tiny graphic images placed on the RWS Applications or in our emails that allow us to determine whether you have performed specific actions. When you access the RWS Applications or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure responses to our communications and improve the RWS Applications and promotions.
We also use embedded scripts which are programming codes designed to collect information about your interactions with the RWS Applications, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the RWS Applications and is deactivated or deleted thereafter.
We use HTML5, another form of collection, in our apps for the iPhone or iPad (and any other Apple iOS device). HTML5 is another form of collection, tracking and storage that does not rely on traditional browser cookies. Like Flash cookies, HTML5 cookies can be used to track users across website but are not stored in browsers’ cookie files. To our knowledge there is currently no known way for a user of a mobile device to remove HTML5 tracking and storage.
In many cases, the information we collect using cookies and other tools is used in non-identifiable ways, without any reference to personal information. For example, we use information we collect about RWS Application users to optimize our Products and Services and understand traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with personal information. Whenever we associate Usage Information or a Device Identifier with your personal information, we will treat it as personal information.
Information You Provide About a Third Party
If you send someone else a communication from the RWS Applications, such as sending an invitation to a friend, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on the RWS Applications, your e-mail address may be included in the communication sent to your friend.
Information We Collect from Third Parties
We acquire information from other trusted sources to update or supplement the information you have provided or that we collected automatically, such as information to validate or update your address or other demographic and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to target our communications so that RWS can inform you of products, services and offers that may be of interest to you and for internal business analysis or other business purposes.
Third Party Analytic Technologies
We use third parties’ analytic and tracking tools to better understand who is using the RWS Applications, how people are using the RWS Applications, how to improve the effectiveness of the RWS Applications and their content and how to serve more targeted advertising to you. Those third-party companies may use cookies, pixel tags or other technologies to collect and store anonymous information such as time of visit, pages visited, time spent on each page of the RWS Applications, Device Identifiers, type of operating system used and other website(s) you may have visited. They might combine information they collect from your interaction with RWS Applications with information they collect from other sources and use this combined information to send you certain marketing or other communications. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies.
If you wish to exercise choice with respect to collection and use of the data by these third-party tools, you may visit: http://www.aboutads.info/choices/
Some of the analytic and tracking tools we may use are Google Analytics and Google Analytics Advertising. The Google Analytics Advertising features we may use include the following:
If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout/
HOW WE USE AND SHARE YOUR INFORMATION
We use your information (including your personal information), subject to applicable laws, for the following purposes:
Authorized Third Party Service Providers. We may use third party service providers (“Authorized Third Party Service Providers”) to help us operate our business and the RWS Applications or administer activities on our behalf. We may share your information with these Authorized Third-Party Service Providers.
Third Parties Who Recommended our Products and Services. From time to time, we may provide to third parties who either purchased on your behalf, or recommended our Products and Services to you (such as realtors who sold or rented you your home), information regarding your use of those Products or Services.
Electronic and Direct Mail Promotional Offers. RWS and our affiliates and subsidiaries may send you promotional emails and direct mailings regarding special offers about our Products and Services or on behalf of third-party marketing partners that may be of interest to you. If you do not want to receive emails or direct mail regarding special promotions or offers you may opt-out as provided in the CHOICE AND OPT OUT section below.
Telemarketing. If you have given us your telephone number, RWS and our affiliates and subsidiaries may use the telephone number you provided to contact you, including to: (a) follow up on your order and (b) market to you renewals or other Products or Services. If you would prefer not to receive marketing phone calls from us, you may opt-out as provided in the CHOICE AND OPT OUT section below.
Third Party Tracking and Advertising. We may allow third-party companies to serve ads or collect certain anonymous information on our behalf when you visit the RWS Applications. These companies may use non-personally identifiable information (i.e., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the RWS Applications and other websites in order to provide advertisements about goods and services that may be of interest to you. These companies typically use a cookie or third-party web beacon to collect this information. If you would like more information about advertisers’ use of tracking technologies and about your option not to accept the cookies used to track your activities, you can go to www.networkadvertising.org.
Co-Branded Areas. Certain areas on our RWS Applications may be provided to you in association with third parties such as advertisers that provide products and services or rewards programs (“Co-Branded Areas”). Such Co-Branded Areas will identify the applicable third party. If you elect to register for the products or services provided at these Co-Branded Areas, you either will be providing your personal information to both us and the applicable third party or we may be providing your personal information directly to such third party. With respect to Co-Branded Areas, your information will be subject to this Privacy Policy as well as the privacy policy and practices of such third party. We are not responsible for the privacy practices of such third parties and we suggest you review the individual privacy policies of each company with whom you establish a relationship (including those third-party sponsors or advertisers within a Co-Branded Area).
Feedback. All comments, feedback or materials submitted by you to us, including feedback, testimonials, images, reviews, questions, comments, suggestions, or ideas (collectively, “Feedback”), shall be received and treated by us on a non-confidential and unrestricted basis (except to the extent such Feedback is subject to certain restrictions under applicable law). In accordance with all applicable law and this Privacy Policy, RWS and its affiliates and subsidiaries will be free to use, display, perform, distribute, copy, adapt, and promote, in any medium now known or later developed, without compensation to you, the Feedback along with all ideas, concepts, know-how, techniques or methodologies contained in such Feedback, for any purpose whatsoever, including without limitation, developing, marketing and selling our Products and Services incorporating such Feedback. You agree that in submitting Feedback, such Feedback will not violate any right of any third party, including any confidentiality, copyright, trademark, privacy or other personal or intellectual property or proprietary rights, and will not cause injury to any person or entity. You further agree that no Feedback you submit will contain libelous or otherwise unlawful, threatening, abusive or obscene material, or contain viruses, commercial solicitations, or any form of “spam”.
Legal Matters; Safety. We may, without your consent, access and disclose your information, any communications sent or received by you (including, without limitation, the contents of any chat, messaging, or other communication posted in the Communication Services), and any other information that we may have about you or your account as may be permitted or required by law (including, but not limited to, court order or subpoena), including to prevent or investigate suspected fraud, violations of our Terms of Use or activity that appears to us to be illegal or may expose us to legal liability. Additionally, in accordance with all applicable law and this Privacy Policy, we may disclose your information and communications in situations that we believe to be: (a) emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat or (b) inappropriate with respect to your conduct on the RWS Applications or when using the Communication Services.
Sale or Transfer of Business or Assets. In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, personally identifiable information (including all personal information) of our customers and visitors to our RWS Applications may be one of the assets sold or merged in connection with that transaction. In addition, information about our customers and registered users may also be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support, or funding.
ACCESS TO YOUR INFORMATION
If you have an online account with us, you may choose to resign and deactivate or otherwise manage your account at any time by visiting My Account. If for any reason you are concerned that the personal information or Financial Information you provided to us is not correct and you wish to change it, please call our Customer Care Department at 1-800-544-8156. We will be happy to review, update or remove information as appropriate. If you deactivate your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, resolve disputes, enforce our Terms of Use or other policies, take actions we deem necessary due to technical and legal requirements, and as dictated by constraints related to the security, integrity, and operation of our RWS Applications. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ privacy practices.
CHOICE AND OPT OUT
To opt-out of marketing communications or to request to be added to our Do Not Call List or our Do Not Mail List, you may use one of these convenient methods:
Electronic Promotional Offers. If you do not want to receive emails regarding special promotions or offers, you may: (a) click the unsubscribe link in the footer of any email; (b) call customer care at 1-800-544-8156 or (c) contact our Privacy Coordinator at the address set forth below.
Direct Mail Promotional Offers. If you do not want to receive promotional offers through direct mail, you may: (a) call customer care at 1-800-544-8156 or (b) contact our Privacy Coordinator at the address set forth below.
Telemarketing. If you do not want to receive marketing phone calls, you may: (a) call customer care at 1-800-544-8156; (b) ask to be placed on our Do Not Call list when you receive a call from us or (c) contact our Privacy Coordinator at the address set forth below.
If you receive marketing communications from RWS or one of its affiliates or subsidiaries, you must opt-out individually from each of the brands from which you are receiving brand-specific marketing communications.
Please note that even if you opt out of receiving promotional electronic or direct mail offers, we may continue to send you service notifications by email or direct mail that are related to your account(s) and our Products and Services you have requested or in which you are currently enrolled.
Service Notification Program. In the event you elect to receive certain notices and announcements via text message (SMS) through RWS’ Service Notification Program, you can opt out of continuing to receive these communications through SMS by texting STOP to the SMS number used by RWS to contact you.
CALIFORNIA RESIDENT PRIVACY RIGHTS
California consumers have a right to knowledge, access, and deletion of their personal information under the California Consumer Privacy Act. California consumers also have a right to opt out of the sale of their personal information by a business and a right not to be discriminated against for exercising one of their California privacy rights. RWS does not sell the personal information of California consumers and does not discriminate in response to privacy rights requests.
RWS provides notice of our privacy practices in our Privacy Policy. The Privacy Policy includes what personal information is collected, the source of the personal information, and the purposes of use, as well as whether RWS discloses that personal information and if so, the categories of third parties to whom it is disclosed.
You or your authorized agent would like to exercise your privacy rights, requests may be made by calling 1-800-544-8156. RWS will ask you for information which we consider necessary to verify your identity for security and to prevent fraud. This information may include name, contact information, and information related to your transaction or relationship with RWS, but the specific information requested may differ depending on the circumstances of your request for your security and to protect privacy rights. If we delete your personal information, we will both render certain personal information about you permanently unrecoverable and also deidentify certain personal information.
DO NOT TRACK. RWS does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. Third parties that have content embedded on RWS’s websites such as a social feature or a stock ticker may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific RWS website from a certain IP address. Third parties cannot collect any other personally identifiable information from RWS’s websites unless you provide it to them directly.
IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION
Links to other Website(s) and Communities. To the extent hyperlinks may be utilized to access external or third-party website(s) and communities, you should be aware that these external or third-party website(s) and communities are not controlled by us and, therefore, are not subject to this Privacy Policy. We recommend that you review the privacy policies of each such website and community to determine how your information will be utilized.
Security. We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. To guard your information delivered to us electronically, the RWS Applications use Secure Sockets Layer (SSL). SSL encrypts your credit card number, name and address so only we are able to decode your information. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your information, to the extent permitted by law, we do not guarantee or warrant the security of any information you transmit to or from the RWS Applications, and you do so at your own risk.
We urge you to keep any password that you establish with us in a safe place and not to divulge it to anyone. Also, we advise that you log off your account and close your browser window when you have finished your visit to an RWS Application. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place.
A Note to International Users. The RWS Applications are operated in the United States. If you are located anywhere outside of the United States, please be aware that information we collect will be transferred to, processed, and stored in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the RWS Applications or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States. You are also consenting to the application of United States federal and Tennessee state law in all matters concerning the RWS Applications and this Privacy Policy.
Children’s Privacy. The RWS Applications are generally intended for general adult audiences and are not directed or intended for children under thirteen years of age. We do not knowingly collect personal information from individuals under thirteen years of age. If you are under thirteen years of age, you should not register or provide personal information on the RWS Applications. If we later obtain actual knowledge that a user who has provided personal information is under thirteen years of age, we will take steps to remove that user’s personal information from our systems.
Changes to the Privacy Policy. We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on the RWS Applications, with the “Effective Date” posted at the top of the Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new RWS Applications or Communication Services or change existing ones. If we make any material changes to this Privacy Policy or how we handle your personal information, you will know either because (a) the Effective Date of this Privacy Policy will change or (b) we will provide you with a copy of the updated Privacy Policy that includes an updated Effective Date. By accessing the RWS Applications or interacting with us after the Effective Date, you are deemed to consent to our then-current Privacy Policy for information captured after the Effective Date of that Privacy Policy.
Disputes. If you choose to visit the RWS Applications your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use including limitations on damages, resolution of disputes, and application of the laws of the United States and the State of Indiana.
No Rights of Third Parties. This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the RWS Applications.
Contacting Us. If you have any questions about this Privacy Policy, or the practices of the RWS Applications and Communication Services, please email us at [email protected] or write to us at:
Office of the General Counsel
Attn: Compliance
PO Box 318
Carmel, IN 46082
This Privacy Policy is being provided to you by RWS of America, LLC, RWS Home Service Contracts, LLC, and Residential Warranty Home Protection of California, Inc. (individually and collectively “RWS”, “we” or “us”) on behalf of itself and certain of its affiliates and subsidiaries. This Privacy Policy applies to information we receive from or about you, including personally identifiable information, in connection with your access or use of: (a) the websites https://residentialwarrantyservices.com, https://homewarrantycalifornia.net, https://rwshomeservicecontracts.com (together with any successor website, the “Site”), (b) other interactive properties, including, but not limited to, any mobile applications enabling you to access the Site (together with the Site, the “RWS Applications”), (c) the products and services provided by RWS, including through the RWS Applications or offline (the “Product(s)” and “Service(s)”), (d) offline communications with RWS, including direct mail, telephone and postal mail and (e) any other means or applications in which you connect with RWS or a third party from whom RWS receives information about you.
By accessing or using the RWS Applications or our Products and Services, registering with, providing personal information to, or communicating with, RWS, you explicitly accept, without limitation or qualification, the collection, use, storage, and transfer (including international transfer) of your personal information in the manner described in this Privacy Policy. THIS PRIVACY POLICY AFFECTS YOUR RIGHTS AND LIABILITIES UNDER THE LAW. If you do not agree to the terms of this Privacy Policy, do not access, or use the RWS Applications, provide us with personal information or otherwise communicate with us.
INFORMATION WE COLLECT
We may collect different types of information about you, depending upon how you interact with us. This information may include personal information, Financial Information, demographic information, log-in information and Device information. Sometimes we collect combinations of all these types of information or aggregate some or all of these types of information to improve the Products and Services and facilitate other legitimate business purposes. In each case, when using the RWS Applications, it is indicated on the RWS Applications whether any personal information or demographic data must be provided for you to access and use the RWS Applications or purchase the requested Product or Service.
Connecting with the RWS Applications and Information Provided by You
When You Register or Otherwise Contact Us. When you provide us with information (including personal information) in connection with a particular activity, you agree that such action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to receiving communications from RWS (and its affiliates and subsidiaries) through the information you provided to us. You also attest that you have the legal authority over any telephone number you provide to us and can provide the authorization to contact you. This means RWS may contact you, in person or by recorded message, by e-mail, telephone or mobile telephone number (including use of automated dialing equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving.
Registration Information. We will collect personal information from you if you register on the RWS Applications or place an order for our Products or Services, which may include, but is not limited to, name, address, phone number(s), and email address(es). You may not use a user/account name that is vulgar or otherwise offensive (as determined by RWS), infringes any trademark or other proprietary rights of others, or is used in any way that violates the terms of use of the Site (the “Terms of Use”). RWS reserves the right to deny, in its sole discretion, any user access to the RWS Applications or our Products and Services without notice, for any or no reason.
Financial Information. Financial information is information that you provide to us, including your bank account number, routing number, debit or credit card number and related billing information (collectively, the “Financial Information”). We require such Financial Information in order to process payment for the purchase of a Product or Service that you have requested. By submitting your Financial Information, you consent to our providing your Financial Information to those Authorized Third Party Service Providers as are reasonably necessary to support and process your transactions as well as your credit card issuer and banking institution. We ask that you do not enter Financial Information into your profile, except in the fields provided for that information.
Facebook. You may be given the option to link your Facebook account so that you can comment on the RWS Applications and your interaction with RWS or take advantage of other features of the RWS Applications. When you comment on the RWS Applications using your Facebook username and password and click “allow” on the Facebook permission authorization screen, we will automatically import all information that you allow to be imported from your Facebook profile based upon your privacy settings at Facebook, such as your location, your interests, etc. (collectively, “Permitted Facebook Profile Content”) and you give us permission to: (a) capture, store, use and display your Permitted Facebook Profile Content, including syncing access to such Permitted Facebook Profile Content when you are not using RWS Applications and (b) otherwise use Permitted Facebook Profile Content as described in this Privacy Policy. The authentication of your Facebook login credentials is conducted solely through Facebook.
User Generated Content. The RWS Applications may contain review or chat areas or other message, communication or other mechanisms designed to enable you to communicate with others or to post content on the RWS Applications (the “Communication Services”). Please remember that any information you disclose while participating with the Communication Services becomes public information, becomes the property of, and is subject to redistribution by, RWS. You should exercise caution and discretion when deciding to disclose your personal information in a submission or posting. There is no expectation of privacy when posting or otherwise participating on the Communication Services. If you post content, such as messages, reviews, or photos, please be aware that any personally identifiable information contained in such content is accessible to registered users or visitors to that RWS Application or Communication Services and we have no control over how those users may use your personally identifiable information. We have the right, but not the obligation, to monitor any activity and content associated with the Communication Services. We reserve the right to take action in connection with any content, including that which we deem inappropriate. Please review our Terms of Use for more information regarding your appropriate use of these Communication Services.
Information Collected Through Technology
In addition to any personal information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs to track and record certain information. As you use our RWS Applications, your browser and devices communicate with servers operated by us, our business partners and our service providers to coordinate and record your activity and fulfill your requests (“Usage Information”). We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access our RWS Applications, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. In addition, we collect your IP address or other unique identifier (“Device Identifier”) from your computer (or other device) used to access the RWS Applications (each, a “Device”). A Device Identifier is a number that is automatically assigned to the Device used to access the RWS Applications, and our computers identify your Device by its Device Identifier. We may also collect information about the website you were visiting before you came to our RWS Applications and the website you visit after you leave our RWS Applications if this information is supplied to us by your browser. We may use this Usage Information for a variety of purposes, including to enhance or otherwise improve the RWS Applications.
The information from cookies and related technology is stored in web server logs and also in web cookies kept on your Device(s), which are then transmitted back to our Site by your Device(s). These servers are operated, and the cookies managed, by us, our business partners or our service providers. For example, when you visit RWS Applications, we and our service providers may place cookies on your Device(s). Cookies allow us to recognize you when you return to an RWS Application and may track and target your interests in order to provide a customized experience. Cookies also help us detect certain kinds of fraud. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the RWS Applications. Some cookies contain serial numbers that allow us to connect your activity with RWS Applications with other information we store about you in your profile or as related to your interactions with RWS Applications.
Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases Session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use Persistent cookies for a number of purposes, such as retrieving certain information you have previously provided. “Flash” cookies, known as local shared objects, are data files placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device to personalize your visit. Our third-party service providers also may use Flash cookies to collect and store information. Flash cookies are different from standard browser cookies because of the amount of, type of, and way data is stored. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. You can choose to have your computer warn you each time a Persistent or Session cookie is being sent, or you can choose to turn off such cookies through your browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. However, cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies, click www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. In some cases, you may be able to disable cookies on your Device. However, if you choose to disable cookies on your Device, some features of the RWS Applications may not function properly. For instance, if cookies are disabled, you will not be able to log into the Site and therefore you will experience an anonymous user experience.
Pixel tags and web beacons are tiny graphic images placed on the RWS Applications or in our emails that allow us to determine whether you have performed specific actions. When you access the RWS Applications or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure responses to our communications and improve the RWS Applications and promotions.
We also use embedded scripts which are programming codes designed to collect information about your interactions with the RWS Applications, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the RWS Applications and is deactivated or deleted thereafter.
We use HTML5, another form of collection, in our apps for the iPhone or iPad (and any other Apple iOS device). HTML5 is another form of collection, tracking and storage that does not rely on traditional browser cookies. Like Flash cookies, HTML5 cookies can be used to track users across website but are not stored in browsers’ cookie files. To our knowledge there is currently no known way for a user of a mobile device to remove HTML5 tracking and storage.
In many cases, the information we collect using cookies and other tools is used in non-identifiable ways, without any reference to personal information. For example, we use information we collect about RWS Application users to optimize our Products and Services and understand traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with personal information. Whenever we associate Usage Information or a Device Identifier with your personal information, we will treat it as personal information.
Information You Provide About a Third Party
If you send someone else a communication from the RWS Applications, such as sending an invitation to a friend, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on the RWS Applications, your e-mail address may be included in the communication sent to your friend.
Information We Collect from Third Parties
We acquire information from other trusted sources to update or supplement the information you have provided or that we collected automatically, such as information to validate or update your address or other demographic and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to target our communications so that RWS can inform you of products, services and offers that may be of interest to you and for internal business analysis or other business purposes.
Third Party Analytic Technologies
We use third parties’ analytic and tracking tools to better understand who is using the RWS Applications, how people are using the RWS Applications, how to improve the effectiveness of the RWS Applications and their content and how to serve more targeted advertising to you. Those third-party companies may use cookies, pixel tags or other technologies to collect and store anonymous information such as time of visit, pages visited, time spent on each page of the RWS Applications, Device Identifiers, type of operating system used and other website(s) you may have visited. They might combine information they collect from your interaction with RWS Applications with information they collect from other sources and use this combined information to send you certain marketing or other communications. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies.
If you wish to exercise choice with respect to collection and use of the data by these third-party tools, you may visit: http://www.aboutads.info/choices/
Some of the analytic and tracking tools we may use are Google Analytics and Google Analytics Advertising. The Google Analytics Advertising features we may use include the following:
- Remarketing;
- Google Display Network Impression Reporting;
- Google Analytics Demographic and Interest Reporting; and
- Integrated services that require Google Analytics to collect data via advertising cookies and anonymous identifiers
If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout/
HOW WE USE AND SHARE YOUR INFORMATION
We use your information (including your personal information), subject to applicable laws, for the following purposes:
- to allow you to register and create an account and profile on the RWS Applications (and elsewhere);
- to share your information (including for marketing and other purposes) with our affiliates and subsidiaries, where we consider appropriate;
- to deliver, provide and process payment for a Product or Service you have requested;
- to enable you to provide us with feedback;
- to administer promotions you enter into such as a contest or sweepstakes;
- to allow your participation in our Communications Services (where available on the RWS Applications);
- to allow your participation in any surveys;
- to prevent transactional fraud and other illegal activity and to protect the rights, property, and safety of us, you and others;
- to alert you to changes and updates in our RWS Applications’ policies, Products or Services;
- to send you communications (including targeted marketing and promotional offers) that may be of interest to you, such as emails or text messages about RWS and its affiliates and subsidiaries and their products or services;
- to customize, measure and improve products, services, content, and advertising, including generating internal reports about the use of our RWS Applications;
- to personalize your overall experience with RWS;
- to enforce our Terms of Use;
- for testing, research, and product development;
- to respond to law enforcement and regulatory requests, or as required by applicable law, regulation, or court order;
- in connection with a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other transaction involving some or all of our assets that include your information;
- for certain other purposes disclosed at the time you provide your information; and
- as otherwise set forth in this Privacy Policy.
Authorized Third Party Service Providers. We may use third party service providers (“Authorized Third Party Service Providers”) to help us operate our business and the RWS Applications or administer activities on our behalf. We may share your information with these Authorized Third-Party Service Providers.
Third Parties Who Recommended our Products and Services. From time to time, we may provide to third parties who either purchased on your behalf, or recommended our Products and Services to you (such as realtors who sold or rented you your home), information regarding your use of those Products or Services.
Electronic and Direct Mail Promotional Offers. RWS and our affiliates and subsidiaries may send you promotional emails and direct mailings regarding special offers about our Products and Services or on behalf of third-party marketing partners that may be of interest to you. If you do not want to receive emails or direct mail regarding special promotions or offers you may opt-out as provided in the CHOICE AND OPT OUT section below.
Telemarketing. If you have given us your telephone number, RWS and our affiliates and subsidiaries may use the telephone number you provided to contact you, including to: (a) follow up on your order and (b) market to you renewals or other Products or Services. If you would prefer not to receive marketing phone calls from us, you may opt-out as provided in the CHOICE AND OPT OUT section below.
Third Party Tracking and Advertising. We may allow third-party companies to serve ads or collect certain anonymous information on our behalf when you visit the RWS Applications. These companies may use non-personally identifiable information (i.e., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the RWS Applications and other websites in order to provide advertisements about goods and services that may be of interest to you. These companies typically use a cookie or third-party web beacon to collect this information. If you would like more information about advertisers’ use of tracking technologies and about your option not to accept the cookies used to track your activities, you can go to www.networkadvertising.org.
Co-Branded Areas. Certain areas on our RWS Applications may be provided to you in association with third parties such as advertisers that provide products and services or rewards programs (“Co-Branded Areas”). Such Co-Branded Areas will identify the applicable third party. If you elect to register for the products or services provided at these Co-Branded Areas, you either will be providing your personal information to both us and the applicable third party or we may be providing your personal information directly to such third party. With respect to Co-Branded Areas, your information will be subject to this Privacy Policy as well as the privacy policy and practices of such third party. We are not responsible for the privacy practices of such third parties and we suggest you review the individual privacy policies of each company with whom you establish a relationship (including those third-party sponsors or advertisers within a Co-Branded Area).
Feedback. All comments, feedback or materials submitted by you to us, including feedback, testimonials, images, reviews, questions, comments, suggestions, or ideas (collectively, “Feedback”), shall be received and treated by us on a non-confidential and unrestricted basis (except to the extent such Feedback is subject to certain restrictions under applicable law). In accordance with all applicable law and this Privacy Policy, RWS and its affiliates and subsidiaries will be free to use, display, perform, distribute, copy, adapt, and promote, in any medium now known or later developed, without compensation to you, the Feedback along with all ideas, concepts, know-how, techniques or methodologies contained in such Feedback, for any purpose whatsoever, including without limitation, developing, marketing and selling our Products and Services incorporating such Feedback. You agree that in submitting Feedback, such Feedback will not violate any right of any third party, including any confidentiality, copyright, trademark, privacy or other personal or intellectual property or proprietary rights, and will not cause injury to any person or entity. You further agree that no Feedback you submit will contain libelous or otherwise unlawful, threatening, abusive or obscene material, or contain viruses, commercial solicitations, or any form of “spam”.
Legal Matters; Safety. We may, without your consent, access and disclose your information, any communications sent or received by you (including, without limitation, the contents of any chat, messaging, or other communication posted in the Communication Services), and any other information that we may have about you or your account as may be permitted or required by law (including, but not limited to, court order or subpoena), including to prevent or investigate suspected fraud, violations of our Terms of Use or activity that appears to us to be illegal or may expose us to legal liability. Additionally, in accordance with all applicable law and this Privacy Policy, we may disclose your information and communications in situations that we believe to be: (a) emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat or (b) inappropriate with respect to your conduct on the RWS Applications or when using the Communication Services.
Sale or Transfer of Business or Assets. In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, personally identifiable information (including all personal information) of our customers and visitors to our RWS Applications may be one of the assets sold or merged in connection with that transaction. In addition, information about our customers and registered users may also be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support, or funding.
ACCESS TO YOUR INFORMATION
If you have an online account with us, you may choose to resign and deactivate or otherwise manage your account at any time by visiting My Account. If for any reason you are concerned that the personal information or Financial Information you provided to us is not correct and you wish to change it, please call our Customer Care Department at 1-800-544-8156. We will be happy to review, update or remove information as appropriate. If you deactivate your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, resolve disputes, enforce our Terms of Use or other policies, take actions we deem necessary due to technical and legal requirements, and as dictated by constraints related to the security, integrity, and operation of our RWS Applications. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ privacy practices.
CHOICE AND OPT OUT
To opt-out of marketing communications or to request to be added to our Do Not Call List or our Do Not Mail List, you may use one of these convenient methods:
Electronic Promotional Offers. If you do not want to receive emails regarding special promotions or offers, you may: (a) click the unsubscribe link in the footer of any email; (b) call customer care at 1-800-544-8156 or (c) contact our Privacy Coordinator at the address set forth below.
Direct Mail Promotional Offers. If you do not want to receive promotional offers through direct mail, you may: (a) call customer care at 1-800-544-8156 or (b) contact our Privacy Coordinator at the address set forth below.
Telemarketing. If you do not want to receive marketing phone calls, you may: (a) call customer care at 1-800-544-8156; (b) ask to be placed on our Do Not Call list when you receive a call from us or (c) contact our Privacy Coordinator at the address set forth below.
If you receive marketing communications from RWS or one of its affiliates or subsidiaries, you must opt-out individually from each of the brands from which you are receiving brand-specific marketing communications.
Please note that even if you opt out of receiving promotional electronic or direct mail offers, we may continue to send you service notifications by email or direct mail that are related to your account(s) and our Products and Services you have requested or in which you are currently enrolled.
Service Notification Program. In the event you elect to receive certain notices and announcements via text message (SMS) through RWS’ Service Notification Program, you can opt out of continuing to receive these communications through SMS by texting STOP to the SMS number used by RWS to contact you.
CALIFORNIA RESIDENT PRIVACY RIGHTS
California consumers have a right to knowledge, access, and deletion of their personal information under the California Consumer Privacy Act. California consumers also have a right to opt out of the sale of their personal information by a business and a right not to be discriminated against for exercising one of their California privacy rights. RWS does not sell the personal information of California consumers and does not discriminate in response to privacy rights requests.
RWS provides notice of our privacy practices in our Privacy Policy. The Privacy Policy includes what personal information is collected, the source of the personal information, and the purposes of use, as well as whether RWS discloses that personal information and if so, the categories of third parties to whom it is disclosed.
You or your authorized agent would like to exercise your privacy rights, requests may be made by calling 1-800-544-8156. RWS will ask you for information which we consider necessary to verify your identity for security and to prevent fraud. This information may include name, contact information, and information related to your transaction or relationship with RWS, but the specific information requested may differ depending on the circumstances of your request for your security and to protect privacy rights. If we delete your personal information, we will both render certain personal information about you permanently unrecoverable and also deidentify certain personal information.
DO NOT TRACK. RWS does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. Third parties that have content embedded on RWS’s websites such as a social feature or a stock ticker may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific RWS website from a certain IP address. Third parties cannot collect any other personally identifiable information from RWS’s websites unless you provide it to them directly.
IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION
Links to other Website(s) and Communities. To the extent hyperlinks may be utilized to access external or third-party website(s) and communities, you should be aware that these external or third-party website(s) and communities are not controlled by us and, therefore, are not subject to this Privacy Policy. We recommend that you review the privacy policies of each such website and community to determine how your information will be utilized.
Security. We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. To guard your information delivered to us electronically, the RWS Applications use Secure Sockets Layer (SSL). SSL encrypts your credit card number, name and address so only we are able to decode your information. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your information, to the extent permitted by law, we do not guarantee or warrant the security of any information you transmit to or from the RWS Applications, and you do so at your own risk.
We urge you to keep any password that you establish with us in a safe place and not to divulge it to anyone. Also, we advise that you log off your account and close your browser window when you have finished your visit to an RWS Application. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place.
A Note to International Users. The RWS Applications are operated in the United States. If you are located anywhere outside of the United States, please be aware that information we collect will be transferred to, processed, and stored in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the RWS Applications or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States. You are also consenting to the application of United States federal and Tennessee state law in all matters concerning the RWS Applications and this Privacy Policy.
Children’s Privacy. The RWS Applications are generally intended for general adult audiences and are not directed or intended for children under thirteen years of age. We do not knowingly collect personal information from individuals under thirteen years of age. If you are under thirteen years of age, you should not register or provide personal information on the RWS Applications. If we later obtain actual knowledge that a user who has provided personal information is under thirteen years of age, we will take steps to remove that user’s personal information from our systems.
Changes to the Privacy Policy. We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on the RWS Applications, with the “Effective Date” posted at the top of the Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new RWS Applications or Communication Services or change existing ones. If we make any material changes to this Privacy Policy or how we handle your personal information, you will know either because (a) the Effective Date of this Privacy Policy will change or (b) we will provide you with a copy of the updated Privacy Policy that includes an updated Effective Date. By accessing the RWS Applications or interacting with us after the Effective Date, you are deemed to consent to our then-current Privacy Policy for information captured after the Effective Date of that Privacy Policy.
Disputes. If you choose to visit the RWS Applications your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use including limitations on damages, resolution of disputes, and application of the laws of the United States and the State of Indiana.
No Rights of Third Parties. This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the RWS Applications.
Contacting Us. If you have any questions about this Privacy Policy, or the practices of the RWS Applications and Communication Services, please email us at [email protected] or write to us at:
Office of the General Counsel
Attn: Compliance
PO Box 318
Carmel, IN 46082