Commitment to Privacy
About Us and This Policy
Who We Are
Robert Charles Lesser & Co., LLC’s (“RCLCO”, “we”, “our” or “us”) operates the Site. This Policy supplements and is governed by our Terms and Conditions (“Terms”). Capitalized terms that are used but not defined in this Policy are defined in our Terms. The Terms describe how the Site works in general, including security measures we use to protect our systems and the information described in the Policy.
When this Policy Applies
This Policy applies to you when you use the Site and anywhere else we gather information about you and refer to this Policy. How we handle your information depends on which Site services you use, and how you use them. By using or accessing the Site, you signify that you have read, understand and agree to be bound by this Policy and the Terms. Please note that:
- If you are a current or former employee or contractor of ours, this Policy does not apply to you. You may contact us about your privacy practices and rights at firstname.lastname@example.org.
- If we receive your information in our role as a service provider to another business, our agreement with that business governs our use of your information. We will refer any questions or concerns of yours to that business.
Because the Site changes often, this Policy may change over time. This Policy is effective as of the Last Updated date above. Anytime we modify the Policy, we will post a revised version on the Site and update the Last Updated date above. If you have given us your contact information, we will notify you before any material changes take effect so you have time to review them.
Collection of Information and Use
Information You Provide
When you register an account with us, sign up for email notifications or respond to surveys, the Site will collect personal information that you voluntarily provide, such as your first and last name, business address, telephone number or e-mail address. These are personal identifiers.
If you purchase a product or service from us, you may also provide payment information. This is commercial information. Please note that your complete payment information, like your full credit card number and security code, is only collected and processed by our payment processor.
Information the Site Collects
As you use the Site, we generate technical data about which features you’ve used, how you’ve used them and the devices you use to access our services, including:
- Device Information related to the device you use to interact with the Site, such as your IP address, its browser and operating system, its internet service provider, and its settings.
- Internet Activity related to your use of the Site, such as the pages you visit, the sites you use before or after visiting ours, your actions within the Site, the content you interact with, general location information, time stamps and performance logs and reports.
Information We Don’t Collect
For clarity, we do not collect, use, sell or share any of these types of information:
- Sensitive personal information
- Personal information about anyone under the age of 18 (see Use by minors for more details)
How We Use Information
We use the information the Site collects to provide you with the best advice and highest-quality service, including by tailoring its content to you and present advertising that may interest you. We may associate information the Site collects with your user account. If you request to receive our newsletter or other marketing communications, we also use your information to provide those communications. You can unsubscribe from communications anytime by clicking ‘unsubscribe’ in any message or by contacting us. We use your information for purposes consistent with your consent, operational business purposes and commercial purposes.
Disclosure of Collected Information
RCLCO only discloses personal information to our corporate affiliates and to service providers who help us provide the functionality and features of the Site.
We may disclose information about you, such as Personal Identifiers, Internet Activity and Device Information, to service providers as necessary for them to perform their services. Our service providers are not permitted to use any information about you for any other purpose. In the past twelve (12) months, we have disclosed these types of information to the following types of contractors:
- Analytics providers, namely Google LLC’s Google Analytics and Google Tags Manager services, to tell us how the Site is doing, such as which parts interest visitors and how long they visit before leaving. Among other data, they may receive your IP address.
- Various hosting services and data processors to provide the infrastructure of the Site, namely Cloudflare, which ensures that traffic is from real people, not computers. Among other data, they may receive your IP address.
- Payment processors and order-fulfillment providers, if you make a purchase from us. Among other data, they will receive your Commercial Information and other order-related information, which may include Personal Identifiers.
We also share information with advertising partners to advertise our products and services to you. In the past twelve (12) months, we have shared these categories of information to personalize advertising:
- Device Information (which may encompass Geolocation data)
- Internet Activity
How Long We Retain Your Information
We retain your information only as long as we need it for the purposes described under Collection of Information and Use, except when longer retention is required by our compliance policies and efforts toward applicable legal, tax, accounting and regulatory requirements.
How long we need information for those purposes varies by category, and even within categories. These retention determinations always consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from its unauthorized use or disclosure, whether we can achieve those purposes without using the personal information.
For example, we delete some Internet Activity at some soon as you exit the Site, whereas we may retain traffic data for analytics purposes and Commercial Information for longer periods of time.
We want you to be in control of your information, so we want to remind you of the following options and tools available to you:
Opting Out of Communications
As described above, we may use the information we collect from you to send messages to you. If you do not want to receive these messages, you can opt out (as applicable) by using the unsubscribe link at the bottom of our communications. You may also at any time opt out of receiving communications from us by contacting us at email@example.com with the subject line “Opt Out”.
Rights under California law
This section applies to you only if you reside in California or another U.S. state where applicable law provides for some or all of these rights or substantially similar rights. Except as noted in this section, we extend these California rights to residents of those states regardless of whether applicable law in those states includes all of these rights.
Rights under CCPA
The California Consumer Privacy Act (“CCPA”) provides California consumers with additional rights regarding their personal information (as defined in CCPA).
The categories of personal information we collect are generally described in Section 3 above, and depend on how you use the Site. For clarity, we have collected personal information related to these CCPA categories of ‘business purposes’ in the last twelve months:
- Advertising and Marketing
- Error Management
- Internal Research
- Provide Products or Services
- Quality Assurance
- Short-Term Transient Use
The categories of service providers to whom we disclose personal information are under above Disclosure of Collected Information.
Under CCPA, California consumers have the following rights:
Rights to Know, Access, Correct and Delete
You have the right to request that we disclose, correct and delete personal information about you that we have collected. Your right to know includes the personal information we have sold or shared or disclosed for a business purpose.
Finally, we may deny deletion requests, in whole or in part, with respect to information we reasonably need to:
- comply with a legal obligation
- allow you, other consumers, or us to exercise free-speech rights or other legal rights
- perform a contract with you
- or if we use the information for solely internal purposes reasonably aligned with consumer expectations.
To submit a request for any of these rights, please submit a request to firstname.lastname@example.org after reviewing the Requesting information section.
Rights to Opt-Out of Sharing/Sale and Limit Use of Sensitive Personal Information
You also have the right to direct us (1) not to share or sell your personal information and (2) limit our disclosure and use of your sensitive personal information to purposes necessary to provide the Site to you.
To opt out of the sharing or sale of your information, please email email@example.com. Because we do not collect sensitive personal information, we do not provide a mechanism to opt out of the use of sensitive personal information.
As of the Last Updated date, we have no knowledge of any use of personal information we collect from individuals under the age of 16 for ‘sale’ or ‘sharing’ purposes.
We are in the process of updating the Site to honor any global opt-out preference signal sent from California IP addresses to the Site through browser or device-level settings, provided the signal complies with CCPA’s requirements. Our goal is for the Site to automatically respond to compliant signals by opting California residents out of any sharing or sale of their data in a frictionless manner.
Please contact us at firstname.lastname@example.org if you believe the Site collected or processed your information in a manner inconsistent with your opt-out preference signal.
Right of No Retaliation
CCPA prohibits us from discriminating against you if you exercise rights under CCPA.
Your right of no retaliation doesn’t need to be exercised. We never retaliate against anyone exercising their rights under CCPA.
Other California law
Because we do not give your information to third parties for direct marketing purposes, we believe we are not currently required to comply with California Civil Code Section 1798.83.
To exercise your Rights to Know, Correct or Delete, please contact at email@example.com. Your request must:
- provide sufficient information to identify you and the law that applies to you, such as your name, e-mail address, home or work address, or other information we maintain.
- not include social security numbers, driver’s license numbers, third-party account numbers, credit or debit card numbers, or health information.
We verify requests by first confirming the source of the request and then by matching the information submitted to the information we maintain. If your request is unclear or we are unable to authenticate your identity, we will respond with direction on how to remedy the deficiencies, in accordance with law that applies to you.
If we cannot verify the identity of the individual making the request, we may deny it, in full or in part.
Responses to requests
We will respond to your request as quickly as we can, taking into account the nature of your request and the volume of pending requests. The content of our response will vary with the nature of your request, but will always respond in accordance with any deadlines or requirements specified by the laws that applies to you.
Under certain circumstances, we may be unable to provide responsive personal information, such as when disclosure would create a substantial, articulable and unreasonable risk to the security of the information, users’ account with us, or the security of our systems or networks. We do not disclose account passwords or any other non-personal information that enables access to a user account.
Please understand, however, that we reserve the right to retain an archive of any information about you, to the extent permitted by law. We may also retain deidentified or aggregate data derived from information about you.
Requests from California residents
The following additional procedures apply only to requests made by California residents.
- California residents may submit CCPA rights requests through an authorized agent.
- Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described below. We will also ask for proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf.
- An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required.
- We will confirm receipt of your CCPA request within 10 days, and will substantively respond within 45 days.
- We may initially substantively respond by informing you that we will require up to 45 further days, along with an explanation of why our substantive response is delayed.
- We provide responses in the manner we receive your request (i.e., with an email response to an email request).
Use by minors
The Site is intended for adults. We do not knowingly collect information from anyone under the age of 16. If we learn that we have collected information from a child under age 16, we will delete that information as quickly as possible.
- If you are under 16: sorry, but please leave the Site. If you’ve already sent us information, please contact us at firstname.lastname@example.org first so we can delete it.
- If you are a parent or guardian of a child under 16 years of age and you believe your child has provided us with information, please contact us at email@example.com.
If you have questions or comments about this Policy, please contact us at firstname.lastname@example.org with “Privacy” in the subject line.
A “cookie” is a small text file placed on your computer’s hard drive by a web server and which is acknowledged by your web browser. On this Site, we may use “cookies” or other technology to gather information about Site usage to help us improve the content, usability and functionality of this Site, to remember certain user attributes (such as the country you are accessing this Site from and your language selection), and/or for targeted advertising purposes. Each time you initiate a session on this Web site, a cookie is set in order to identify you and determine your access privileges. Cookies do not store any of the information that you have provided to the site. This helps us better tailor this Site for users and better understand how many new and repeat users visit this Site, which features or pages are most popular, and user browsing and usage patterns.
You can set parameters on your computer that allow you to elect to accept cookies or to have your browser notify you each time a cookie is offered. You can also usually delete cookies from your hard drive. However, you should know that cookies may be necessary to provide you with access to much of the content and many of the features of this Web site. We use cookie technology to enable registered users to move quickly and securely through access-controlled areas of the sites. Cookie technology also enables registered users to take advantage of certain useful features on the sites, including “remember my password.” Instructions on how to accept cookies, on how to be notified that a cookie is being offered and on how to delete cookies are available through your Internet Browser.
Links to Other Sites
This RCLCO Web site contains links to other Web sites. Please be aware that RCLCO is not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our sites and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies solely to information collected by RCLCO on this Web site.
Notification of Policy Changes
RCLCO reserves the right to amend or modify this policy from time to time. We urge you to review this statement whenever you visit this Site in order to obtain the most current policy statement.