1.2 ABS is the data controller of your personal data. You can contact us by mail at the above address, by email at customercare@abs.com or by telephone at (626) 271-1580. References in thisprivacy policy to “we”, “us” and “our” are to ABS.
2.1 Thisprivacy policy tells you about how we use, protect and disclose your personaldata that we have collected using both offline means (e.g. via phone, post,in-person meetings and other correspondence) and online means, such as when youuse the ABS.com website and our programsand services (collectively, the “Site”).
2.2 You acknowledge that your personal data (including personal data collected throughyour use of our services, and the Site), will be collected, stored, shared and processed in accordance with this privacy policy.
2.3 The Site may contain links to other third-party websites or applications. Please be aware that these websites and applications may collect information about you.These websites and applications may have their own privacy notices or policies. We encourage you to be aware when you leave the Site and to read the privacystatements of each and every website and application that you use.
2.4 Tothe extent any linked websites or applications you visit are not owned or operated by ABS, please be aware that we arenot responsible or liable for the websites’ or applications’ content, any use of the websites or applications, or the privacy and security practices andpolicies of those websites or applications.
3.1 Wemay collect the following data about you. Please note that we may combine personal data collected about you from one source with personal data that wehave collected about you from other sources.
(a) Personal data provided voluntarily including interactions(e.g. reviews, feedback, comments, testimonials)
We collect personal datathat you, or an individual authorized to act on behalf of you (the“Representative”), voluntarily provides to us. We also collect personal data you provide to uswhen you post a testimonial, feedback, review or comment on the Site. This personal data may include your name and contact information, photos that youchoose to upload and other personal data you may choose to provide as part ofyour post. We do not access photos on your device or cameras unless you allowus to do so. If you do allow us, you can manage your photos and camera settingsat any time by changing the settings on your mobile device.
Please note that personal data that you choose to post in a testimonial, feedback,review or comment may be read, collected and used by anyone. Therefore, please do not post anything you do not wish to be accessed by others.
(b) Correspondence
We collect personal datawhere you contact us or we contact you, and we will typically keep a record ofsuch correspondence. This personal data may include your name and contact information, account information, your order information, your queries, and other personal data you may choose to provide to us.
(c) Informationstored on a Device
We may access metadata and other informationassociated with other files stored on your computer, tablet, mobile phone, orany other device (referred to collectively as a “Device”) such as IP address, domain name, browser version and operating system, traffic data,web logs and other communication data, and device identifiers. We may also collect photos, videos, Touch ID and Face ID login abilities and session IDs for third party service providers such as paymentproviders (“Device Information”). Tothe extent required by applicable law, we will ask for your consent prior to collecting Device Information. Please note that we may associate Device Information with your account. In addition, we may associate a Device with youraccount. We may combine this information with other information that we havecollected about you.
(d) Collectionand use of public information
We may also collect, use, store, transfer, share,and disclose your personal data that is publicly available for the purposes setout in this privacy policy.
Children
The Site is intended for use byadults only. ABS does not sell products intended for purchase by children anddoes not therefore knowingly or intentionally collect personal data fromchildren. Youth-oriented products are sold for purchase by adults only. Pleaseonly use this Site if you are aged 18 or over.
4.1 We may use your personal data for a variety of business purposes, which we haveset out below.
(a) To conduct our business and provide you with our services and access to our Site
To conduct our business, including to enable you touse our services and Site, to respond to your queries, to carry out our obligations arising from any agreements entered into between you and us and tocontact you in connection with the foregoing.
(b) To communicate with you (about updates and changes)and provide you with customer support
To communicate with you about updates to our terms,services and Site and to provide you with customer support and to respond toyour requests, comments, questions, or concerns, and to contact you if we havetrouble processing your order. Such communications are provided by variousmeans, including emails. Calls may be recorded for training and monitoring purposes.
(c) In relation to fraud prevention
To prevent fraud as may be required by applicablelaw and regulation and best practice at any given time. If false or inaccurate information is provided and fraud is identified or suspected, details may bepassed to fraud prevention agencies and may be recorded by us or by them.
(d) To allow you to use interactive features of the Site
To allow you to post testimonials, reviews or comments. Please note thatsuch testimonial, review or comment may be read, collected and used by anyone.
(e) To ensure our Site content is relevant and to maintain the security of our Site
To ensure that content from our Sites is presentedin the most effective and secure manner for you and for your device.
(f) For research and development purposes
To analyse your personal data in order to betterunderstand your and our other clients’ services and marketing requirements, tobetter understand our business and develop our products, services and Site. Inorder to do this, we may apply profiles to you based on your personal data and behavioural information (such as the pages on the Site you have visited orinteracted with, including by reference to personal data legitimately obtainedand shared with us by third parties or publicly available data). Such profilesmay be used as part of our advertising, analytics, security and provision of support.
(g) Website analytics
To understand and analyse your online experiencesand to determine what events, products and services are likely to be of interest to you, we may combine your visitor session information or other information collected through tracking technologies (whether you are logged inor not) with personal data.
(h) To enforce our terms and in connection with legalor regulatory obligations
We may process your personal data to enforce ourterms and to comply with our legal and regulatory requirements or dialogue withregulators/judicial proceedings/court orders as applicable which may include disclosing your personal data to third parties, the court service and/orregulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in theworld or where compelled to do so.
(i) To reorganise or make changes to our business
In the event that we: (i) are subject tonegotiations for the sale of our business or part thereof to a third party;(ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal data to the relevant third party (orits advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer yourpersonal data to that re-organised entity or third party after the sale orreorganisation for them to use for the same purposes as set out in this policy.
We use cookies and similar technologies (includingdevice identifiers) in relation to the Site.
5.1 What are cookies?
A cookie is a small text file that is generated by a website, including the Site,and is stored on your device. When you access the Site, a number of cookiesused by ABS and third parties are sent to your browser and stored on yourdevice. When you next visit the Site, ABS and the third parties will use thisinformation to recognise and remember your device. Third parties may also use this to recognise you when you are on other websites and mobile applications. Cookiesare useful for a variety of purposes. For example, they allow you to navigate between pages efficiently and allow us to remember preferences and generally improve your user experience. They are also used to tailor advertising to yourinterests through tracking your browsing across websites. Session cookies are deleted when you close your browser. Persistent cookies remain onyour device after you close your browser. Cookies set by ABS are first-party cookies. Cookies set by third parties are third-party cookies. Please note thatABS has no access to, or control over, third-party technologies and informationabout their data collection practices should be found on their respective websites.
5.2 What cookies does ABS use?
We describe below the categories of cookies that areset by ABS and its partners when you visit the Site.
(a) Strictlynecessary cookies
These cookies are essential in order to enable youto move around the Site and use its features and cannot be turned off. Withoutthese cookies, services you have asked for cannot be provided. Therefore, youcannot disable these cookies.
(b) Performance cookies
We make use of performance cookies to analyse howour visitors use the Site and to monitor the Site’s performance. This allows usto provide a high quality experience by customising our offering, and quicklyidentifying and fixing any issues that arise.
For example, we might use performance cookies tokeep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. The information collected by these cookies is not associated withyour personal data by us or by our contractors.
(c) Functional cookies
These cookies are used to provide you with certain functionality on the Site. Forexample, to improve theperformance of our services and the Site, to maintain security on the Site andto prevent and detect fraud, and to display certain web page content based uponyour browser type and other device information.
(d) Advertising cookies
ABS andvarious third party ad partners may use cookies and other tracking technologiesto collect information about the browsing habits associated with your device tofurther personalise your experience such as through the use of targetedadvertisements and special offers that are more relevant to you and your interests. We mayallow some third parties, includingFacebook, to set cookies both when you visit our Site and when you use certain features on our Site (such as clicking “Like”, “Share” and “tweet” buttons). These third parties link the information that they collect through the use of thesecookies with the information that they hold about you through your use of their service in order to present you with targeted advertising via their platforms. Inother situations, third parties use cookies so that they can retarget Rosewill’s products to you when you visit other websites or mobile applications, or topredict what advertisements about third party products are likely to be ofinterest to you based on your browsing activities.
5.3 Other tracking technologies
In conjunction with cookies, we may utilise other tracking technologies to understand how you access and use our Site and services. These tracking technologies may include:
(a) Log files and IP address
We use device information and IP addresses (and ask for confirmation if this iscorrect) to analyse trends, administer the Site, track user movement, andgather broad demographic information for aggregate use. An IP address is anumeric code that identifies your computer on the internet. We may store theinformation in log files (i.e. files which record events), or other types offiles, which may be combined with other information that we have collected about you.
(b) Web Beacons and pixels
The Site and our emails and advertisements may contain web beacons. A web beacon isa small graphic image, such as a pixel or GIF, which is placed on a web page,email, or advertisement and is used to provide information on when and how youaccess and use the Site, and services and emails. We may use this information for various purposes, including to develop statistical information and todetermine features that most interest you for the purpose of providing morepersonalised content. With respect to emails, we may use this information todetermine which of our emails are more interesting to you and whether you wishto continue receiving such emails if you do not open them. The pixel will bedeleted when you delete the email. If you do not wish the pixel to bedownloaded to your device, you should select to receive emails from us in plaintext rather than HTML, and you should not click links that we send you.
5.4 “Do Not Track Signals”
Someweb browsers have a “Do Not Track” feature that, when turned on, signals to websites the user visits that the userdoes not want to be tracked. At this time, the Site does not respond to “Do NotTrack” signals or similar mechanisms. If you would like additional information about online tracking andvarious opt-out mechanisms, please see https://youradchoices.com
5.5 Managing and disable cookies on the Site
Our website
You can manage cookies throughyour browser’s settings (http://allaboutcookies.org provides explanations as to how to do this). Please note that some of the uses of theSite and the services provided on the Site may not function if cookies are disabled. Please notethat not all tracking will stop even if you delete cookies.
We may share or disclose your personal data for the purposes set out in section 4above to third parties. These third parties include:
(a) Service providers
Such service providers may include:
· Third-partycompanies to perform functions on our behalf e.g. data analysis; and
· ITcloud and hosting providers.
(b) Advisors
Such advisors may includelegal, financial, business or other advisors.
(c) Other users of the Site
As mentioned above, anypersonal data you make available publicly such as by your reviews, comments ortestimonials will be shared with other users of the Site.
(d) Affiliated companies
We may share your personal data we collect with allABS parent companies, subsidiaries, and affiliates.
As our business continues to evolve, we mayacquire, establish or sell business units or subsidiaries. Customer data is oneof the business assets that would be transferred in these types oftransactions. In such a situation, your personal data would only be used in amanner consistent with this privacy policy.
(e) Thirdparties as required by law or regulation
We may disclose your personal data as required bylaw or regulation, and when we believe that disclosure is necessary to protectour rights and/or comply with a judicial proceeding, court order, or legalprocess served on ABS.
We may collect, use, store, transfer, share, anddisclose non-personal information for any purpose (subject to applicable law).
Security
8.1 Nodata transmission over the Internet or websites can be guaranteed to be securefrom intrusion. However, ABS takes commercially reasonable efforts to protectits customers’ personal data.
8.2 Ifyou have any questions or concerns about ABS’s security practices, you can sendus an email at customercare@abs.com.
General overseas transfers
9.1 Our servers andoffices are located in the United States, and as a result, we may collect,process, store, share, and transfer your personal data in the United States.
9.2 As such, youunderstand and acknowledge that your personal data may be accessed by staff orsuppliers in, transferred to, and/or stored at, a destination outside thecountry in which you are located, including to our servers and offices in the United States.
9.3 These countries may not provide the same level of data protection as your home country; however, we will take steps to ensure that your personal data that is transferred outside your home country is safeguarded inline with this privacy policy.
10.1 Ourretention periods for personal data are based on business needs and legal requirements.
10.2 Wewill retain your personal data while we are using it, for purposes described inthe section 4 above. We may continue toretain it after we have ceased such uses for certain legitimate businesspurposes. We may also continue to retainyour personal data to meet our legal requirements or to defend or exercise ourlegal rights.
10.3 Thelength of time for which we will retain your personal data will depend on thepurposes for which we need to retain it. After we no longer need to retain your personal data, we will delete itor securely destroy it in accordance with our records retention policy.
11.1 ABS operates in states with data protection laws which provide differentrights to individuals in respect of access, deletion, rectification andlimiting processing of personal information. When you submit a request toexercise your rights, we will need to check yourentitlement prior to answering a request. Please note that your rights may besubject to certain exemptions as set out in applicable data protection law(s).
11.2 In general, the right to require us to update any inaccuracies inthe personal data we hold is likelyavailable to you regardless of where you are located.
11.3 In some states you have certain rightspertaining to your personal data, including: the right to delete, the right toopt out, the right to access your Personal data, and the right not bediscriminated against. To exercise your rights under any applicable law,excluding the California Consumer Privacy Act (the “CCPA”), pleasesubmit a verifiable request to us by emailing customercare@abs.com or by contacting usas per section 1 of the privacy policy above. If you are a resident of California, please seeAppendix 1 for additional information concerning your rights under the CCPA.
11.4 Contacting us
If you have any queries or complaints about our use of your information, please contact us directly at customercare@abs.com.
Cookie Settings
12.1 You can manage cookies through your browser’s settings.
13.1 We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If these changesare material, we will take steps to inform you of these.
13.2 We will update the date of this document each time it is changed.
The privacy policy contained herein became officially effective September 27th 2020
WhereCalifornia privacy laws apply (if you are a consumer resident in California) the following additional provisions apply:
i. The provisions of this section I apply inaddition to section 3, section 4 and section 6 of the privacy policy.
ii. The information that we collect is set out inthe main body of the Privacy Policy. We further detail it below in accordance with California privacy requirements:
Identifiers such as areal name, alias, postal address, unique personal identifier, onlineidentifier, internet protocol address, email address, account name, or othersimilar identifiers.
To perform serviceson behalf of ourselves, including providing you customer service and for the purposes set out in section 4 of the privacypolicy.
Personal information is sold or disclosed in accordance with section 6 of the privacy policy. Recipients include service providers[1]; advisors; other Site users (where applicable); our affiliated companies; ; and other parties as required for legal and regulatory purposes.
Your signature,physical characteristics or description, telephone number, insurance policynumber, bank account number, credit card number, debit card number, or anyother financial information, medical information, or health insuranceinformation.
To perform serviceson behalf of ourselves, including servicing your account and providing youcustomer service and forthe purposes set out in section 4 of the privacy policy.
Personal characteristics, such as your gender, age, date of birth, citizenship status,and marital status.
Commercial information, including records products or services purchased, obtained, orconsidered, or other purchasing or consuming histories or tendencies.
N/A
Biometric information
N/A
Internet or otherelectronic network activity information, including, but not limited to,browsing history, search history, and information regarding a consumer’sinteraction with an internet web site, application, or advertisement.
Auditing related to acurrent interaction with the consumer and concurrent transactions, including,but not limited to, counting ad impressions to unique visitors, verifyingpositioning and quality of ad impressions, and auditing compliance with thisspecification and other standards and for the purposes set out in section 4 of the privacy policy.
Geolocation data
To perform serviceson behalf of ourselves, including providing you customer service and for the purposes set out in section 4 of the privacypolicy
Audio, electronic,visual, thermal, olfactory, or similar information
N/A
Professional oremployment-related information
N/A
Educationinformation, defined as information that is not publicly available personallyidentifiable information as defined in the Family Educational Rights andPrivacy Act.
N/A
Inferences drawn fromany of the information identified in this subdivision to create a profile abouta consumer reflecting the consumer’s preferences, characteristics,psychological trends, predispositions, behavior, attitudes, intelligence,abilities, and aptitudes.
To perform services on behalf of ourselves, including providing you customer service and for the purposes set out in section 4 of the privacy policy.
Any other suchpersonal information as set out in section 4 of the privacy policy.
To perform serviceson behalf of ourselves, including providing you customer service and for the purposes set out in section 4 of the privacypolicy.
iII. We may aggregate orde-identify any personal information that we collect in connection with our services, such that theinformation is no longer personally identifiable or attributable to you. We mayuse such aggregated information for our own legitimate business purposeswithout restriction.
iv. We do not sell thepersonal information of minors under 16 years of age without affirmativeauthorization.
i. The provisions of this section II apply inaddition to section 11 and section 12 of the privacy policy.
ii. As a California resident, you have the right:
· to request access tothe personal information we have about you;
· to request that wedelete personal information about you;
· to opt-out of ouruse, transfer, exchange or disclosure (including to third parties) of personalinformation about you; and
· not to be discriminated against based upon whether you decide to opt-out.
iii. You have the right torequest that we disclose to you what information we collect, use, disclose, andsell. Under California law, “sell,”“selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing,disseminating, making available, transferring, or otherwise communicatingorally, in writing, or by electronic or other means, a consumer’s personalinformation by the business to another business or a third party for monetaryor other valuable consideration. Youalso have the right to request that a business delete any personal informationabout you which we have collected about you. We do not “sell” personalinformation under the California privacy laws. We do not sell the personal information ofminors under 16 years of age without affirmative authorization.
iv. Please note for yourprotection, any request sent to us to access or delete your personalinformation will be subject to the following verification procedure: upon yoursubmission of a request using one of the methods described in paragraph viii,below, we will send an email confirmation to the email address we have on filefor you requiring you to confirm your request. When you have completed thistwo-step process ABS will verify theinformation that you provide in your request against information we have onfile for you. We reserve the right todeny your request if we cannot verify your identity. Where we deny your request in whole or inpart, we will endeavor to inform you of the denial, provide an explanation of our actions, andprovide the reasons for the denial.
v. ABS does not sellpersonal information.
vi. We shall notdiscriminate against you for exercising any of your above rights.
vii. You may designate anauthorized agent to make a request to exercise your rights on your behalf. Todesignate an authorized agent to make a request to exercise your rights underthe CCPA on your behalf, then please complete and return the Agent Authorization Form. Your authorized agent must be able to provideto us written proof that you have authorized the agent to act on yourbehalf. For your protection, we reservethe right to deny any request from an agent who does not submit proof that theyhave been authorized to act on your behalf. We reserve the right to deny any request from an agent if we cannotverify your identity or the agent’s identity.
viii. To exercise the accessand deletion rights described above, please submit a verifiable consumerrequest to us by contacting us as per section 1 of the privacypolicy above.
[1] Service providers are legal or naturalpersons who perform services for us or on our behalf, including for thepurposes of operating our website and apps, assisting us to perform businessfunctions and operations, and fulfilling requests by you. This could include, and is not limited to, web hosting providers, app hostingproviders, IT systems administrators, mailing houses, couriers, paymentprocessors, data entry service providers, electronic network administrators,and professional advisors such as accountants, solicitors, business advisorsand consultants