Rossiter Masters | Privacy Policy

Privacy Policy

Last Update: December 1st, 2019

Registration Information: At the time you register for a newsletter, course or to become a Registered User of the Site, you will be asked to complete a registration form which requires you to provide information such as your name, address, phone/fax number, email address and other personal information as well as information about your business (“Registration Information.”)

Publishing Information: If you submit any information to RM to be published on the Site through the publishing tools, then you are deemed to have given consent to the publication of such information so long as they do not pertain to personal information (“Publishing Information”).

Buyer Information: we record and retain records of buying and browsing activities on our platform including but not limited to IP addresses, browsing patterns, buyer behavioral patterns, buyer contact details, buyer profiles and so forth (“Buyer Information”).

Payment Information: If you establish a credit account with us or our providers or if you purchase a product or service from RM or other Registered Users of the Site or other vendors available through the Sites, we may collect additional information, including billing information, credit card numbers and expiration dates and tracking information from checks or money orders (“Payment Information”).

Account Activities Information: We record and retain the records of your Account activities when you use the RM services. If you make the sale and purchase transactions online through RM’s web-based transaction platform, we also collect information related to such transactions including the types and specifications of the goods, pricing and delivery information, any trade dispute records (“Account Activities Information”).

Statistical Information: In addition, we gather statistical information about our Site and Users, such as IP addresses, browser software, operating system, software and hardware attributes, pages viewed, number of sessions, unique visitors and so forth (“Statistical Information”)

Marketing Information: From time to time, we gather information about our users and prospective users during trade shows, marketing events and other functions for follow up marketing purposes (“Marketing Information”).

Personal Information: From time to time, our Users may disclose personal data deliberately or inadvertently including without limitation to personal identifiers such as name, email addresses, telephone number, facsimile number and IP address of individuals in the course of using the Site (“Personal Information”).

Collected Information: Registration Information, Publishing Information, Buyer Information, Payment Information, Account Activities Information, Statistical Information, Marketing Information, Personal Information and any information we may collect from you through the use of cookies (see Section 5 below), or from our affiliates or from other parties or through any other means, shall collectively be referred to as (“Collected Information”).

General: We use your Collected Information to improve our marketing and promotional efforts, to statistically analyze site usage, to improve our content and product offerings and to customize our Site’s content, layout and service specifically for you. We may use your Collected Information to service your Account with us, including but not limited to investigating problems, resolving disputes and enforcing agreements with us. We may use your Collected Information to facilitate proper operation of our Site and business activities of its Users including without limitation to facilitation of effective communication between buyers and suppliers and marketing activities of Users. We do not otherwise sell, rent, trade or exchange any personally-identifying information of our Users. We may provide your Collected Information to our affiliates and service providers under contract (such as customer care) to support the operation of the Site and our services. If you register or use services or products provided by our affiliates, we will share with each other your Collected Information including the information about your use of such affiliates’ services and products. We may share certain aggregate information based on analysis of Collected Information with our partners, customers, members, advertisers or potential Users. We may use your Collected Information to execute marketing campaigns, promotions or advertising messages on behalf of third parties; however, in these circumstances, your Collected Information will not be disclosed to such third parties unless you respond to the marketing, promotion or advertising message. Your Collected Information may be transferred, stored, used and processed outside your home jurisdiction. In case of a merger with or transfer of the business to another business entity, we will transfer your Collected Information to the entity which acquires the business (Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your Collected Information).

Registration Information: We may use your Registration Information to provide services that you request or to contact you regarding additional services about which RM determines that you might be interested in. Specifically, we may use your email address, mailing address, phone number, mobile number or fax number to contact you regarding notices, surveys, product alerts, new service or product offerings and communications relevant to your use of our Site. We may generate reports and analysis based on the Registration Information for internal analysis, monitoring and marketing decisions.

Publishing Information: All of your Publishing Information will be publicly available on the Site and therefore accessible by any internet user. Any Publishing Information that you disclose to RM becomes public information and you relinquish any proprietary rights (including but not limited to the rights of confidentiality and copyrights) in such information. You should exercise caution when deciding to include personal or proprietary information in the Publishing Information that you submit to us.

Payment Information: RM will share your Payment Information with banks or vendors relevant to the transaction in order to enable transactions to be completed. In addition, RM may use Payment Information to determine your credit-worthiness and, in the process of such determination, RM may make such Payment Information available to banks or credit agencies. While RM has in place up-to-date technology and internal procedures to guard your Payment Information against intruders, there is no guarantee that such technology or procedure can eliminate all of the risks of theft, loss or misuse. RM shall not be liable to you or any other person for any damages that might result from unauthorized use, publication, disclosure or any other misuse of Payment Information, including credit card information.

Account Activities Information: We use Account Activities Information to provide the services that you request. We may also generate reports, statistics, and analysis based on Account Activities Information to enhance and improve our Site and services. We may also use Account Activities Information to determine your credit-worthiness.

Statistical Information: We use Statistical Information to help diagnose problems with and maintain our computer servers, to manage our Site, and to enhance our Site and services based on the usage pattern data we receive. We may generate reports and analysis based on the Statistical Information for internal analysis, monitoring and marketing decisions. We may provide Statistical Information to third parties, but when we do so, we do not provide personally-identifying information without your permission.

Buyer Information: We use Buyer Information to provide value-added services to our members including without limitation to providing buying patterns and buying behavioral data to our members to facilitate marketing initiatives and decision-making.

Personal Information: We facilitate electronic commerce between businesses and our services should not be used by individual consumers or for personal use. Should Personal Information be disclosed for business purposes in the course of using our Site and services, such Personal Information may be used to provide value-added services to our members to facilitate including without limitation marketing initiatives and contacts. Uses of any Personal Information by any of our members are subject to privacy laws in the respective jurisdictions of our members. Each of our members is solely responsible for observing applicable laws and regulations in its respective jurisdictions to ensure that all use of the Site and Services are in compliance with the same. Each of our members is expressly prohibited from using any Personal Information for illegal activities including without limitation to spamming.

Personalizing, improving or operating our Products and business

Better understanding your needs and interests

Fulfilling requests, you make related to the Products

Providing you with information and offers from us or third parties

Complying with our legal obligations, resolving disputes with users, enforcing our agreements

Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity

To process your orders and deliver the Products that you have ordered

To provide reports based on information collected from the use of our Products

To keep you up to date on the latest Product announcements, software updates, software upgrades, system enhancements, special offers, and other information

To provide support and assistance for our Products

To provide the ability to create personal profile areas and view protected content

To provide the ability to contact you and provide you with shipping and billing information

To provide feedback and support

To provide and administer opt-in contests, sweepstakes or other marketing or promotional activities on the Rossiter or affiliate websites

To the extent, you choose to participate, to conduct questionnaires and surveys in order to provide better products and services to our customers and end-users

To support recruitment inquiries

To personalize marketing communications and website content based on your preferences, such as in response to your request for specific information on products and services that may be of interest

To meet contract or legal obligations

Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.

Rectification: If you believe that any Personal Data, we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your member account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.

Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.

Erasure: You can request that we erase some or all of your Personal Data from our systems.

Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.

Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Products.

Right to File Complaint: You have the right to lodge a complaint about Rossiter’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

This is the Privacy Policy governing your use of the RM websites (the “Site”) and the collection, use, transfer and processing of your Collected Information by Rossiter Masters LLC., EVE LLC and our affiliates (collectively referred to as “RM”, “we”, “RM” or “us”). By using this Site, you consent to our Privacy Policy set out below. All terms not defined in this document have the meanings ascribed to them in the Terms of Use between you and RM which by use of this Site you agree to accept.

This policy outlines our handling practices and how we collect and use the Personal Data you provide during your online and offline interactions with us. As used in this Privacy Policy, ”Personal Data“ means any information that can be used to individually identify a person, and may include, but is not limited to, name, email address, postal or other physical address, credit or debit card number, title, and other personally identifiable information.

If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.

RM will be the controller of your Personal Data that is provided, collected and/or processed pursuant to this Privacy Policy, except where otherwise expressly stated below. If you have any questions about whether any of the foregoing applies to you, please contact us using the information set forth in the “Contact Us” section on the RM website.

This policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to our website.

The Information We Collect

How We May Use Information

Processing of your Personal Data

We will use your Personal Data only in accordance with our Privacy Policy. If you do not wish us to continue using your Personal Data in this manner, you can request that your account be deactivated by contacting us as specified in the “Contact Us” section.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your user agreement with us that allows us to provide you with the Products) and our “legitimate interests” or the legitimate interest of others (e.g. our users) such as:

We process Personal Data for purposes such as:

Choice

You can choose whether to provide Personal Data to RS but note that you may be unable to access certain options, offers, and services if they require Personal Data that you have not provided. You can sign-up, and therefore consent, to receive email or newsletter communications from us. If you would like to discontinue receiving these communications, you can update your preferences by using the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this policy.

Data Subject Rights

You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.

To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.

Data Retention

How long we retain your Personal Data depends on the type of data and the purpose for which we process the data.

Passive Collection

RM and our third-party service providers automatically collect some information about you when you use our Products, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website and/or Products.

In addition, when you use some of our Products, network information is transmitted back to us such as Product usage information. This information is transmitted back to us so we can determine how users are interacting with our Products, to assist us with improving our Products, and to correct any problems that may occur.

Disclosure of Information

We may publish records of complaints and any penalties, actions or proceedings against Members. We further reserve the right to disclose your Collected Information to relevant authorities where we have reason to believe that such disclosure is necessary to identify, contact or bring legal action against someone who may be infringing or threatening to infringe, or who may otherwise be causing injury to or interference with, the title, rights, interests or property of RM, our Users, customers, partners, other web site users or anyone else who could be harmed by such activities.

We also reserve the right to disclose Collected Information in response to a subpoena or other judicial order or when we reasonably believe that such disclosure is required by law, regulation or administrative order of any court, governmental or regulatory authority.

If we have reason to believe that a User is in breach of the Terms of Use or any other agreement with us, then we reserve the right to make public or otherwise disclose such User’s Collected Information in order to pursue our claim or prevent further injury to RM or others.

Co-Branded Relationships

We have established relationships with other parties to offer you the benefit of other products and services that we ourselves do not offer. We offer you access to these other parties either through the use of hyperlinks to their sites from our Site, or through offering “co-branded” sites in which both ourselves and these other parties share the same uniform resource locator, domain name or pages within a domain name on the Internet. In some cases, you may be required to submit information for purposes of registering or applying for products or services provided by such third parties or co-branded partners. The privacy policy of such other parties may differ from ours, and we may not have any control over the information that you submit to such third parties or co-branded sites. We therefore encourage you to read that policy before responding to any offers, products or services provided by such other parties.

We use “cookies” to store specific information about you and track your visits to our Site. It is not uncommon for websites to use cookies to enhance the identification of their users. A “cookie” is a small amount of data that is sent to your browser and stored on your computer’s hard drive. A cookie can be sent to your computer’s hard drive only if you access our Site using the computer. If you do not de-activate or erase the cookie, each time you use the same computer to access our Site, our web servers will be notified of your visit to our Site and in turn we may have knowledge of your visit and the pattern of your usage. Generally, we use cookies to identify you and enable us to access your Registration Information, Publishing Information, Buyer Information, Personal Information, or Payment Information so you do not have to re-enter it; gather statistical information about usage by Users; research visiting patterns and help target advertisements based on User interests; assist our partners to track user visits to the Site and process orders; and track progress and participation in promotions.

You can determine if and how a cookie will be accepted by configuring your browser, which is installed in the computer you are using to access the Site. If you desire, you can change those configurations in your browser. By setting your preferences in the browser, you can accept all cookies, you can be notified when a cookie is sent, or you can reject all cookies. If you reject all cookies by choosing the cookie-disabling function in your browser, you may be required to re-enter your information on our Site more often and certain features of our Site may be unavailable.

Interest-Based Advertisements

We partner with third parties to either display advertising on our website or to manage our advertising on other sites. Some of our third-party partners use technologies such as cookies and other technologies to gather information about your activities on this website, our affiliates’ websites, and unaffiliated websites in order to provide you advertising based upon your browsing activities and interests. With respect to our interest-based ads, we adhere to self-regulatory principles for online behavioral advertising issued by the Digital Advertising Alliance (“DAA”) and the European Interactive Digital Advertising Alliance (“EDAA”) (collectively, the “OBA Principles”).

More information about the OBA Principles can be found at https://digitaladvertisingalliance.org/principles and https://www.edaa.eu/european-principles/. If you wish to not have information about your online activities over time and across different websites used for the purpose of serving you interest-based ads, you can opt-out by clicking here and here (or if located in the EU click here). Please note that (1) this does not opt you out of being served ads, and even if you opt-out of interest-based ads, you will continue to receive generic ads and (2) we store your opt-out preference for interest-based ads in a cookie on your device, and therefore you may have to opt-out again if you delete your cookies.

Mobile Application

When you download and use our Products, we automatically collect information on the type of device you use, operating system version, and the device identifier (or ”UDID“). We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you can turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

Geolocation

We collect information about where you are located when you are using our Products. We use this information for purposes such as optimizing your connection to our data center and suggesting customizations to your experience with our Products (e.g. your language preference). We share this information with parties such as our data center provider and our advertising partners. If you do not wish to allow us to share your information in this manner please opt-out by contacting us at Ruth@rossitermasters.com.

Sharing your Personal Data

We do not sell or rent your Personal Data to third parties for marketing purposes unless you have granted us permission to do so.

We share Personal Data within RM and its affiliated companies, and with third-party service providers for purposes of data processing or storage.

We also share Personal Data with business partners, service vendors and/or authorized third-party agents or contractors in order to provide requested Products or transactions, including processing orders, processing credit card transactions, hosting websites, hosting event and seminar registration and providing customer support. We provide these third parties with Personal to complete/utilize the requested Product or transaction.

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy. As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.

We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of RM’s terms of service, or as otherwise required by law.

While navigating RM’s website or Products, you may be directed to content or functionality that is hosted by a third-party. When information is collected on behalf of RM exclusively, RM’s Privacy Policy will be referenced and will govern how your information is used. For other, non-Rossiter sites or services, the site/service owner’s privacy policy will be referenced. You should review such third party’s privacy and security policies prior to use.

Security of your Personal Data

RM is committed to protecting the Personal Data you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. When we transfer credit card information over the Internet, we protect it using Secure Sockets Layer (SSL) encryption technology.

We recommend you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your Personal Data, you can contact us at Ruth@rossitermasters.com

Linked websites and third-party services

Our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this policy. We encourage you to review the privacy policies posted on these (and all) sites you visit or services you use.

Newsgroups/forums

If you participate in a discussion forum or Support chat, you should be aware that the information you provide there will be made broadly available to others, potentially inside or outside RM, who have access to that discussion forum or Support chat. Also, please recognize that individual forums and chat rooms may have additional rules and conditions. Each participant’s opinion on a forum or chat room is his or her own and should not be considered as reflecting the opinion of RM.

Minors

The Site and its contents are not intended to be targeted to minors under applicable law and we do not intend to sell any of our products or services to minors. However, we have no way of distinguishing the age of individuals who access our Site and so we carry out the same Privacy Policy for individuals of all ages. If a minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact us to remove the information.

Security Measures

We employ commercially reasonable security methods to prevent unauthorized access, maintain data accuracy and ensure correct use of information.

As a Registered User, your Registration Information, Publishing Information and Payment Information (if any) can be viewed and edited through your Account, which is protected by a password. We recommend that you do not divulge your Password to anyone. Our personnel will never ask you for your Password in an unsolicited phone call or in an unsolicited e-mail. If you share a computer with others, you should not choose to save your login information (e.g., User ID and Password) on the computer. Remember to sign out of your Account and close your browser window when you have finished your session.

No data transmission over the Internet or any wireless network can be guaranteed to be perfectly secured. As a result, while we try to protect your information, no web site or company, including ourselves, can absolutely ensure or guarantee the security of any information you transmit to us and you do so at your own risk.

Transfer and Storage of Personal Data

Our Products are hosted and operated in the United States (“U.S.”) through RM and its service providers. We may transfer your Personal Data to the U.S., to any RM affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage. By using any of our Products or providing any Personal Data for any of the purposes stated above, you consent to the transfer and storage of your Personal Data, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers.

Changes to Privacy Policy

Any changes to this Privacy Policy will be communicated through our posting an amended and restated Privacy Policy on our Site. Our posting the amended and restated Privacy Policy will make such new Privacy Policy immediately effective. You agree that all Collected Information (whether or not collected prior to or after the new policy became effective) will be governed by the newest Privacy Policy then in effect. If you do not agree to the new changes in our Privacy Policy, you should contact RM in writing (at the address set out in the “Your Feedback” section below) and specifically request that RM return and/or destroy all copies of all or part of your Collected Information in RM’s possession.

Accessing and Correcting Your Information

You can access, view and edit your Registration Information, Publishing Information and Payment Information (if any) through your Account with RM.

Your feedback

RM welcomes your continuous input regarding our Privacy Policy or our services provided to you. You may send us your comments and responses to RM at Ruth@rossitermasters.com

We reserve the right to make changes to this policy. Any changes to this policy will be posted.

If you reside in the EU, United Kingdom, Lichtenstein, Norway or Iceland, you can also contact our Data Protection Officer https://rossitermasters.com/official-statement-eu-gdpr-compliance/.

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