Privacy Notices

We may collect personal information when you interact with us or any of our brands or affiliates, such as when you:

• Access, use, visit, register through, or purchase or return goods or services via the Websites;

• Consent to receive our promotional emails, SMS/text messages, job postings or other communications;

• Provide information from your emails, texts, live chats, video calls and voice calls with our representatives;

• Participate in our contests, sweepstakes or promotions, or participate in one of our surveys or other customer research;

• Submit product ratings and reviews;

• Contact us or one of our service providers with a comment, question or complaint; or

• Enroll or participate in one or more of our customer, loyalty, rewards, or other programs.

We may also collect personal information from certain third parties, such as third-party marketing providers. We limit collection of personal information to what is reasonably necessary and proportionate to perform the stated purposes or provide the requested product or service requested.

We do not use or disclose your sensitive personal information (as such term is defined under applicable state laws) for purposes other than those permitted by law, such as providing our products and services, ensuring security, and complying with legal obligations. We do not sell your sensitive personal information, or share your sensitive personal information, such as for the purpose of cross-context targeted advertising. We do not use geolocation or create geofences to identify, track, or target individuals based on consumer health data, including near healthcare facilities.

We may anonymize, de-identify, or aggregate data we collect or receive and may use and/or disclose such data in de-identified form for any business purpose, including sharing with third parties. To the extent that we maintain and/or use any de-identified personal data, we will not attempt to re-identify such information unless permitted by applicable law.

We may collect, analyze, monitor, record, and use information regarding your visits and interactions with our Websites, including IP addresses and unique identifiers, browsing activity, video search, selection, and viewing activity, session replays, searches conducted through the Websites and via third-party search engines, and communications submitted through live chat or similar functionality, and we may share such information with our service providers, analytics providers, advertising partners, and other third parties as described in this Privacy Policy.

We may use third parties to facilitate or improve our ability to identify and/or track visitors to our website. As part of this service, we may make available personal information and identifiers to these third parties including our visitors’ IP addresses, names, cookies, and hashed versions of email addresses captured from your visit. We may also use advertising, tracking, and analytics technologies including pixels, web beacons, browser plug-ins, software development kits (SDK), and other storage, identifying, and tracking, technologies from third parties, including Meta and other social media platforms, to share, collect or receive information from the Websites and elsewhere on the internet. Third parties, including Meta, use that information to provide measurements services, target and deliver ads, and for similar cross context tracking and behavioral advertising. Web beacons are small, transparent graphic images on a web browser or HTML email, typically implemented as GIF, PNG or similar image files (often referred to as “pixels”) which are used to track visitor activity on the website or email. They may be used in conjunction with javascript or other tags and technologies to facilitate tracking and identifying visitors. Additionally, we and third parties use this data to obtain more information about our visitors and reach out to them through other channels, such as targeted ads, email, and/or direct mail. This allows us and third parties to analyze the usage of our site, enhance, and personalize your digital experience, and serve you tailored advertising content (including on third-party websites). We also collect and share information about your visit and use of our site with our social media, advertising and analytics partners who may combine it with other information that you have provided to them or that they have collected from your use of their services. You have the right to opt-out of targeted advertising/sharing of your personal information and any sales of your personal information by using our webform or by contacting us using the contact information provided to you below.

Subject to applicable law, we may disclose your personal information (1) if we are required to do so by law, regulation or legal process, such as a subpoena; (2) in response to requests by government entities, such as law enforcement authorities; (3) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (4) in connection with an investigation of suspected or actual unlawful activity. For example, we may disclose your personal information with the relevant courts or other judicial or official bodies in the context of providing our services or where we are asked to respond to an order or other binding request. We also may disclose your personal information to protect our rights or property or those of our customers or others for the purpose of fraud prevention and other regulatory requirements, including compliance with anti-money laundering, antiterrorist financing, Know Your Customer requirements, and credit risk reduction.

We may disclose your personal information to third parties in the event we sell or transfer (or contemplate the sale or transfer of) all or portions of our business or assets or in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation of our business (“Business Transactions”). In the event of such Business Transactions, such third parties may use your personal information in the same way as set out in this Notice.

You may also exercise the following rights by using our webform or by contacting us using the contact information provided to you below:

1. Right to Access: You have the right to obtain a copy of your personal information we collected about you.

2. Right to Delete: You have the right to delete all or some of the personal information we have collected about you, subject to certain exceptions permitted under applicable law. Removal may not encompass all possible locations; for example, back-ups, information in our systems for business purposes such as transaction records and warranty information.

3. Right to Correct: You have the right to change, update or correct inaccurate personal information that we maintain about you. If offered as a feature of the Websites, you may be able to edit some of the information about you.

4. Right to Opt-Out: You have the right to opt-out of the sale or sharing of your personal information.

You can opt-out of receiving interest-based advertisements based on your internet browsing data by visiting a third party site, such as the DAA opt-out page at www.aboutads.info/choices.

---

RETENTION OF PERSONAL INFORMATION

We only keep the personal information that we collect from you for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The criteria we use to determine the retention period includes the nature of the information, the purpose for which the information was collected, and whether a legal obligation requires us to retain the information. We may also retain aggregate information for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

---

PERSONAL INFORMATION OF MINORS

We do not knowingly collect personal information directly from children under the age of thirteen (13) (or such other digital age of consent in your jurisdiction, for example, sixteen (16) years of age in certain European countries) (each a “Minor”) without parental consent. The Websites are general audience sites and are not specifically targeted to or intended for use by consumers under the age of eighteen (18). We do not knowingly collect personal information directly from known children above the age of thirteen (13) and under the age of eighteen (18) without affirmative authorization from the consumer. If we learn we have collected or received personal information from a Minor without verification of parental consent or from a known child above the age of thirteen (13) and under the age of eighteen (18) without affirmative authorization, we will delete that information or take other action required by applicable law. If you believe we might have any unauthorized information from or about a Minor or a known child above the age of thirteen (13) and under the age of eighteen (18), please contact us using the contact information we provided to you below.

---

TRACKING USER ACTIVITY AND OPT-OUT PREFERENCE SIGNALS

Certain web browsers allow users to enable a Do Not Track privacy preference setting that allows users to opt out of tracking by websites and online services. There is not a common understanding of how to interpret these Do Not Track signals so, to the extent permitted by law, our Websites do not currently respond to Do Not Track signals.

You may set your browser or device to send an opt-out preference signal, such as through the Global Privacy Control, to signal a request to opt-out of the sale or sharing of your personal information or a request to opt-out of the processing of your personal information for the purpose of targeted advertising. Where required by applicable law, we will recognize and process any valid opt-out preference signal by honoring such opt-out preference signal as a request to opt-out of the sale and sharing of your personal information and/or a request to opt-out of the processing of your personal information for the purpose of targeted advertising for your browser or device and any consumer profile associated with your browser or device in accordance with applicable law. For more information on opt-out preference signals, please visit https://globalprivacycontrol.org.

---

SECURITY

We have implemented reasonable security practices and procedures appropriate to the nature of each category of personal information that we collect from you to prevent unauthorized access, destruction, disclosure, modification and use of your personal information. If you create an account through the Websites, please select strong login credentials and do not share your password. Please contact us if you have any concerns regarding the security of your account or personal information.

---

USE OF COOKIES

When you use our Websites we may collect information using a variety of methods, such as cookies and pixel tags. We use cookies to personalize content and advertisements, improve website effectiveness and functionality, provide social media features, and analyze our traffic. A “cookie” is a small data text file, which a website stores on your computer’s hard drive (if your Web browser permits) that can be retrieved later. Our cookies, pixel tags, and other technologies may store, transmit, or process that information, or share that information with third parties including, without limitation, randomly assigned user identification numbers, the country where you are located, your name, your IP address and other identifiers, and interactions with our Websites, including video searches, selection, and viewing activity, Website search queries and search activities, including using third-party search engines and tools to conduct searches and sharing those search and information with third parties, and live chat communications. The cookies make your use of the Websites easier, make the Websites run more smoothly and help us improve the security of the Websites. You are always free to decline our cookies if your browser permits, but some parts of our Websites may not work properly as a result.

We use the following types of cookies:

• STRICTLY NECESSARY COOKIES. These are cookies that are required for the operation of our Websites and to provide our services to you and our customers. They include, for example, cookies that enable you to log into secure areas of our Websites.

• ANALYTICAL/PERFORMANCE COOKIES. These cookies allow us to recognize and count the number of visitors to the Websites and to see how visitors navigate and use our Websites. This helps us for our legitimate interests of improving the way our Websites work, for example, by ensuring that users are finding what they are looking for easily.

• FUNCTIONALITY COOKIES. These cookies are used to recognize you when you return to our Websites. For example, this enables us to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region), and items you may have previously browsed, searched or reviewed, or placed in a shopping cart (if applicable).

• TARGETING/ADVERTISING COOKIES. These cookies record your visit to our website, the pages you have visited and the links you have followed. We may use this information subject to your choices and preferences to make our Websites and the advertising displayed on our Websites more relevant to your interests. We may also share this information with third parties for this purpose.

This information collected by these cookies may constitute personal information if it is capable of identifying you. In these circumstances, this information is subject to the provisions of these Notices.

---

LINKS TO WEBSITES

Except as otherwise discussed in these Notices, these Notices only address the use and disclosure of information we collect. Other sites accessible through our Websites have their own privacy notice and data collection, use and disclosure practices. Please consult each site’s privacy notice. We are not responsible for the policies or practices of third parties. You should contact these third parties directly if you have any questions about their use of the information that they collect.

---

RIGHTS OF COLORADO, CONNECTICUT, DELAWARE, FLORIDA, INDIANA, KENTUCKY, MARYLAND, MINNESOTA, MONTANA, NEBRASKA, NEW HAMPSHIRE, NEW JERSEY, OREGON, RHODE ISLAND, TENNESSEE, TEXAS, AND VIRGINIA RESIDENTS

To the extent we are acting as a “controller” under each respective state law, this section applies to Colorado Consumers, as defined by the Colorado Privacy Act (the “CPA”), Connecticut Consumers, as defined by the Connecticut Data Privacy Act (the “CTDPA”), Delaware Consumers, as defined by the Delaware Personal Data Privacy Act (the “DPDPA”), Florida Consumers, as defined by the Florida Digital Bill of Rights (the “FDBR”), Indiana Consumers, as defined by the Indiana Consumer Data Protection Act (the “INCDPA”), Kentucky Consumers, as defined by the Kentucky Consumer Data Privacy Act (the “KCDPA”), Maryland Consumers, as defined by the Maryland Online Data Privacy Act (the “MODPA”), Minnesota Consumers, as defined by the Minnesota Consumer Data Privacy Act (the “MNCDPA”), Montana Consumers, as defined by the Montana Consumer Data Privacy Act (the “MTCDPA”), Nebraska Consumers, as defined by the Nebraska Data Privacy Act (the “NDPA”), New Hampshire Consumers, as defined by the New Hampshire Privacy Act (the “NHPA”), New Jersey Consumers, as defined by the New Jersey Data Privacy Act (the “NJDPA”), Oregon Consumers, as defined by the Oregon Consumer Privacy Act (the “OCPA”), Rhode Island Consumers, as defined by the Rhode Island Data Transparency and Privacy Protection Act (the “RIDTPPA”), Tennessee Consumers, as defined by the Tennessee Information Protection Act (the “TIPA”), Texas Consumers, as defined by the Texas Data Privacy and Security Act (the “TDPSA”), and Virginia Consumers, as defined by the Virginia Consumer Data Protection Act (the “VCDPA”) that use our Websites. Capitalized terms defined in the CPA, CTDPA, DPDPA, FDBR, INCDPA, KCDPA, MNCDPA, MTCDPA, NDPA, NHPA, NJDPA, OCPA, RIDTPPA, TDPSA, TIPA, or VCDPA that are used in this section shall have the same meaning as in the CPA, CTDPA, DPDPA, FDBR, INCDPA, KCDPA, MNCDPA, MTCDPA, NDPA, NHPA, NJDPA, OCPA, RIDTPPA, TDPSA, TIPA, or VCDPA, as applicable.

We may Process your personal information for Targeted Advertising. You have the right to opt-out of the Processing of your personal information for Targeted Advertising, as described below

If you are a Colorado, Connecticut, Delaware, Florida, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, or Virginia Consumer, subject to certain conditions and restrictions set forth in the CPA, CTDPA, DPDPA FDBR, INCDPA, KCDPA, MODPA, MNCDPA, MTCDPA, NDPA, NHPA, NJDPA, OCPA, RIDTPPA, TDPSA, TIPA, or VCDPA, as applicable, and other applicable laws, you may have the following rights with regard to your personal information:

1. Right to Access. You have the right to confirm whether we are Processing your personal information, to access your personal information, and to ask that we provide you a copy of the personal information we have collected or processed about you in a portable and, to the extent technically feasible, readily usable format. Oregon Consumers also have the right to (i) confirm whether we have Processed your personal information and the categories of your personal information we are Processing or have Processed, and (ii) obtain, at our option, a list of specific third parties to which we have disclosed either (1) your personal information or (2) any personal information. In addition, Delaware and Minnesota Consumers have the right to obtain a list of the specific third parties to which we have disclosed your personal information or, if we do not maintain this information in a format that identifies the specific consumer, a list of specific third parties to whom we have disclosed any consumers’ personal information. Maryland and Tennessee consumers also have the right to obtain the copy in a format that allows you to transmit the data to another controller without hindrance, where the process is carried out by automated means.

2. Right to Correct. You have the right to correct inaccuracies in your personal information. If offered as a feature of the Websites, you may be able to edit some of the information about you.

3. Right to Delete. You have the right to delete personal information that we have collected from or obtained about you.

4. Right to Opt-Out of Sales. You have the right to opt-out of the Sale of your personal information.

5. Right to Opt-Out of Targeted Advertising. You have the right to opt out of the processing of your personal information for purposes of Targeted Advertising. If offered as a feature of the Websites, you may be able exercise this right in part via the Websites.

6. Right to Opt-Out of Profiling. You have the right to opt-out of our processing of personal information for purposes of profiling. We do not offer a way for you to submit such a request because our profiling does not result in decisions that produce legal or similarly significant effects.

7. Right to Withdraw Consent. You have the right to withdraw your consent to our Processing of your sensitive personal information. We do not collect or Process your sensitive personal information and therefore, we do not offer a way for you to submit such a request.

8. Right to Appeal. If you are unsatisfied with our actions related to the exercise of one of your privacy rights above, you have the right to appeal our decision.

You, or your authorized agent if allowed by state law, may exercise the above rights by contacting us using the contact information we provided below or by using this link to submit the request via our webform. If you make a privacy rights request, we will retain the personal information provided to us to fulfill your request for our record keeping purposes. To protect the security of your personal information, depending on the nature of your request, you or your authorized agent may be asked to provide information to verify your identity before your request can be processed. We will confirm receipt of your request and respond to your request as soon as we reasonably can and no later than legally required.

If your authorized agent submits the request, we may deny the request if we are unable to authenticate, with commercially reasonable effort, your identity and your authorized agent’s authority to act on your behalf. If you choose to submit a request to access, a request to delete, or a request to correct, you must include with your request information that we can use to verify your request, which may include, for example, your name, address, email address, phone number, and any other information applicable to your request and to assist us in verifying your identity. We will verify your request by comparing the information you provided in your request to the information we have previously collected about you.

You have the right to not receive discriminatory treatment for exercising these privacy rights. We do not discriminate against you because you have exercised your privacy rights and we do not do the following as a result of your choice to exercise the privacy rights outline in these Notices: charge different rates for goods or services; provide a different level, quality, or availability of goods or services; or suggest any of the preceding will occur.

---

RIGHTS OF CALIFORNIA RESIDENTS

To the extent we are acting as a “controller” under state law, this section applies to California Consumers, as defined by the California Privacy Rights Act (the “CPRA”) that use our Websites. Capitalized terms defined in the CPRA that are used in this section shall have the same meaning as in the CPRA.

If you are a California Consumer, subject to certain conditions and restrictions set forth in the CPRA and other applicable laws, you may have the following rights with regard to your personal information:

1. Right to Access: You have the right to (i) confirm whether we are processing your personal information and (ii) obtain a copy of your personal information we collected about you in a structured, commonly used and machine-readable format.

2. Right to Delete: You have the right to delete all or some of the personal information we have collected about you, subject to certain exceptions permitted under Section 1798.105 of the CPRA. Removal may not encompass all possible locations; for example, back-ups, information in our systems for business purposes such as transaction records and warranty information.

3. Right to Correct: You have the right to change, update or correct inaccurate personal information that we maintain about you. If offered as a feature of the Websites, you may be able to edit some of the information about you.

4. Right to Opt-Out: You have the right to opt-out of the sale or sharing of your personal information.

5. Right to Limit: You have the right to request that certain businesses limit the use of your sensitive personal information to certain uses permitted under Section 1798.121 of the CPRA. We do not collect, use, or disclose your sensitive personal information and therefore, we do not offer a way for you to submit such a request.

You or your authorized agent, provided that you have given your authorized agent signed written permission, may exercise your rights listed above by contacting us using the contact information we provided to you below or by using this link to submit your request via our webform. Depending on the nature of your request, you or your authorized agent may be asked to provide information to verify your identity before your request can be processed. We will confirm receipt of your request and respond to your request as soon as we reasonably can and no later than legally required.

If your authorized agent is submitting the request, we may deny the request if the agent does not provide us with (1) a power of attorney that is valid under California law, or (2) your signed written permission that the agent has been authorized to act on your behalf. If you choose to submit a request to access, a request to delete, or a request to correct, you must include with your request information that we can use to verify your request, which may include, for example, your name, address, email address, phone number, and any other information applicable to your request and to assist us in verifying your identity. We will verify your request by comparing the information you provided in your request to the information we have collected about you.

You have the right to not receive discriminatory treatment for exercising these privacy rights. We do not discriminate against you because you have exercised your rights under the CPRA, and we do not do the following as a result of your choice to exercise any rights as outlined in these Notices: charge different rates for goods or services; provide a different level or quality of goods or services; or suggest any of the preceding will occur. If you are an employee, applicant or independent contractor, you will not be retaliated against for exercising your rights under the CPRA.

---

RIGHTS OF UTAH AND IOWA RESIDENTS

To the extent we are acting as a “controller” under each respective state law, this section applies to Utah Consumers, as defined by the Utah Consumer Privacy Act (the “UCPA”), and Iowa Consumers, as defined by the Iowa Consumer Data Protection Act (the “ICDPA”) that use our Websites. Capitalized terms defined in the UCPA or ICDPA, as applicable, that are used in this section shall have the same meaning as in the UCPA or the ICDPA, as applicable.

 

We may Process your personal information for Targeted Advertising. You have the right to opt-out of the Processing of your personal information for Targeted Advertisin, as described below.

If you are a Utah or Iowa Consumer, subject to certain conditions and restrictions set forth in the UCPA or the ICDPA, as applicable, and other applicable laws, you may have the following rights with regard to your personal information:

Right to Access. You have the right to confirm whether we are Processing your personal information, to access your personal information, and to ask that we provide you a copy of the personal information we collected from you in a portable, readily usable format, to the extent technically practicable.

1. Right to Delete. You have the right to delete personal information that we have collected from or obtained from you.

2. Right to Opt-Out of Sales. You have the right to opt-out of the Sale of your personal information.

3. Right to Opt-Out of Targeted Advertising. You have the right to opt out of the processing of your personal information for purposes of Targeted Advertising. If offered as a feature of the Websites, you may be able exercise this right in part via the Websites.

4. Right to Appeal. If you are an Iowa Consumer and are unsatisfied with our actions related to the exercise of one of your privacy rights above, you have the right to appeal our decision.

You or, in the case of a known child or a consumer subject to guardianship, conservatorship, or other protective arrangement, your parent, guardian or conservator (each an “authorized agent”), as applicable, may exercise the above rights by contacting us using the contact information we provided below, or using this link to submit the request via our webform. If you make a privacy rights request, we will retain the personal information provided to us to fulfill your request for our record keeping purposes. To protect the security of your personal information, depending on the nature of your request, you or your authorized agent may be asked to provide information to verify your identity before your request can be processed. We will confirm receipt of your request and respond to your request as soon as we reasonably can and no later than legally required.

If your authorized agent is submitting the request, we may deny the request if we are unable to authenticate, with reasonable effort, your identity and your authorized agent’s authority to act on your behalf. If you choose to submit a request to access or a request to delete, you must include with your request information that we can use to verify your request, which may include, for example, your name, address, email address, phone number, and any other information applicable to your request and to assist us in verifying your identity. We will verify your request by comparing the information you provided in your request to the information we have previously collected about you.

You have the right to not receive discriminatory treatment for exercising these privacy rights. We do not discriminate against you because you have exercised your privacy rights and we do not do the following as a result of your choice to exercise the privacy rights outline in these Notices: deny a good or service, charge different rates for goods or services; provide a different level of quality of goods or services; or suggest any of the preceding will occur.

---

CALIFORNIA’S SHINE THE LIGHT LAW

Under California’s “Shine the Light” law (California Civil Code Section 1798.83), if you are a California resident, you may opt-out of the disclosure of your personal information to third parties for such third parties’ direct marketing purposes. You may also request that we provide you with (1) a list of the categories of information disclosed by us to third parties for such third parties’ direct marketing purposes during the immediately preceding calendar year and (2) the names and addresses of all of the third parties to whom we disclosed your personal information to for direct marketing purposes in the immediately preceding year. To exercise your rights under California’s “Shine the Light” law, please contact us using the contact information we provided to you below.

---

RIGHTS OF NEVADA RESIDENTS

We do not sell (as defined under Nevada law N.R.S. 603A.333) any Covered Information (as defined under Nevada law N.R.S. 603A.320). If we do so, we will let you know in these Notices and you will have the right to opt out of the selling of certain Covered Information under Nevada law by contacting us using the contact information we provided to you below, or as otherwise provided in these Notices or the Websites. If you would like to make a further inquiry regarding the sale of your Covered Information, please contact us using the contact information we provided to you below.

---

UNSUBSCRIBING FROM OUR EMAIL LIST

If you would like to unsubscribe from our email list, please contact us or use the unsubscribe link in one of our emails to you and we will remove your name from our email list. Please understand that you may receive emails between the time you request to be removed from our list and the time we are able to process your request. Email communications are not encrypted and are not considered a secure means of transmitting credit card numbers or other payment information. We will never ask for sensitive information via email.

---

CONTACT US

Please get in touch with us if you have any questions about these Notices, the practices of the Websites, your dealings with the Websites, or would like to exercise any of your rights afforded by applicable law. You may contact us by mail at the following address:

Information & Computing Services, Inc.

3563 Philips Highway, Suite F-601

Jacksonville, Florida 32207

 

You may also contact us by email at info@rfsmart.com with “Privacy” in the subject line or at our toll-free number +1 970-422-5022.