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Paul Ropp, Ltd. (“Paul Ropp”) respects your privacy and is committed to taking reasonable steps towards protecting your privacy online and managing your information responsibly, in order to best understand the products and services that are most useful to you.  This Privacy Policy is intended to notify you of our online privacy practices, the type and categories of information that may be collected, disclosed and stored, how the information is used, with whom the information may be shared, what choices are available to you regarding the collection, use and distribution of the information, what kind of security procedures are in place to protect the loss, misuse or alteration of information under our control, your rights regarding your personal information and who to contact with questions or concerns.

This Privacy Policy applies to the Paul Ropp stores; the websites located at www.paulropp.com, and to any phone, fax, and/or mail operations concerning processing of orders and questions about products or services, as well as our marketing contacts with you.  This Privacy Policy does not apply to other websites to which we may link, or to other companies or persons who might be listed as third-party contacts or suppliers on the Website, or to whom we may refer you if you call or write us.  We may post links on the Website as a way of helping you locate related information and products easily.  However, when linking to another website, you must review that website’s privacy notice as other websites may not treat information collected online in the same manner as we do.  This Privacy Policy also does not apply to information collected when you purchase our products in department and specialty stores, or on other third-party websites where our products are sold.  Unless otherwise specified, personal information collected from these other channels Paul Ropp has no control over how they use the information that they collect.

By using the Website and/or by contacting us and providing any personal information, you consent to the collection and use of information by us in accordance with this Privacy Policy, as well as the Website Terms of Use.  If we decide to change our Privacy Policy, we will post those changes on this page and, at the end of this Privacy Policy, indicate the date that changes were last made.

WHY WE COLLECT INFORMATION:

We collect personal information because it helps us improve and deliver our products and services.  In addition, your personal information helps us communicate to you our latest products, special offers, and information and events about which you might like to hear.  We also collect your personal information to help us design and deliver our Website, and to deliver targeted marketing to you based on your interests and previous purchases.  We also may correlate your personal information obtained from you with information from other sources.  For example, if you provide us with your personal information, we may cross-check that against information that might be otherwise available through other entities such as when you, or a business with which you are affiliated, seeks to open a credit account with us, or in order to prevent or detect fraud.

WHAT INFORMATION WE COLLECT:

The following generally describes the type of information we may collect about you.  Those who wish to communicate with us but do not wish to provide personal information online may contact us through the address or phone numbers provided on our Website, or through our online chat function.  However, you should note that if you contact us by phone, online chat or via postal mail, you may still be submitting personal information to us, as set forth herein.

We may collect, and over the prior 12 months have collected, the following categories of personal information:

Identifiers, such as name, contact information (e.g., postal, mailing, billing, and/or shipping address, zip code, email address, telephone number), IP address, loyalty number, government-issued ID number (e.g., driver’s license, passport, or other ID number), a unique PayPal identifier, SM Pass membership number, and other similar identifiers;

Categories of personal information related to the California Customer Records statute (Cal. Civ. Code § 1798.80), such as name, contact information, government-issued ID numbers, checking account information, payment card information (e.g., credit or debit card numbers);

Commercial information, including information about a consumer’s purchase, such as the items purchased, the price of the items, the payment method used, and whether the product was on sale;

Audio, electronic and visual information, such as in-store video monitoring and call recordings created in connection with our business activities (e.g., customer service calls for training and quality control purposes);

Internet or other electronic network activity information, such as browsing history, search history, or information on a consumer’s interaction with our Website;

Geolocation Data, such as your current location (based on your IP address); and

Protected classification characteristics under California or federal law, such as age (40 years or older).

The specific types of personal information we collect are described in detail below.

In-Store Shopping:

When you buy products or obtain services in our stores, we ask you for information we need to process your purchase or provide you with the services you request, such as your name, mailing address, email address, telephone number, zip code, or loyalty number.  Depending on the payment method you use, and only as permitted by applicable law, we may ask for information to verify your identity or to prevent fraud, such as your name, mailing address, telephone number, zip code, driver’s license or ID number, passport number, checking account information or payment card information.  You may refuse to provide such information, but you may not be permitted to complete your purchase if we cannot verify your identity.  If you do provide us with such information, you consent to it being used in accordance with this Privacy Policy.  We may also collect information about your purchase, such as the items purchased, the price of the items, the payment method used, and whether the product was on sale.

We may also use in-store video monitoring for security and quality control. In furtherance of our security policy, in-store video may be used, at our discretion, to assist law enforcement in investigations and may also be turned over to governmental authorities, agencies or others pursuant to an order issued or authorized by a court of competent jurisdiction.  Images captured by our in-store video monitoring will be maintained for a limited period of time.

Telephonic Shopping and Customer Support:

You may call our customer service line for information about our products or personal shopping advice.  If you do so, we may ask you for information such as your name, email address, postal address, telephone number and, if you choose to make a purchase, your payment card information.  We use this information to respond to your requests and process your transactions.

Online Shopping:

When you order products or services from the Website, we will collect the information necessary to complete your order, such as your name, e-mail address, shipping address, payment information (including credit card number and/or PayPal identifier) and billing address and/or shipping address.  You may also provide us with other information that you might submit.  If you create an account, we will collect information about your purchases and payment methods, as well as the shipping addresses that you add to your address book, in order to make future shopping experiences faster and more convenient.

General Browsing:

We collect information, including personal information, you voluntarily submit, such as during a registration or ordering process, when you submit questions or comments, request information or participate in online surveys, contests, promotions or other activities.  Should you voluntarily provide us with personal information, you consent to our use of it in accordance with this Privacy Policy.

Even if you do not submit personal information through the Website, we gather navigational information about where visitors go on the Website and information about the technical efficiencies of our Website and services (i.e., time to connect to the Website, time to download pages, etc.).  This information allows us to see which areas of our Website are most visited and helps us better understand the user experience.  This helps us improve the quality of the Website by recognizing and delivering more of the features, areas, and services our visitors prefer.  In this process of gathering information, we may collect personally identifiable and non-personal information (for example, domain type, browser type and version, third party vendor and IP address, referring/exit pages, operating system, date/time stamp, and click-stream data).  We may also create and use electronic records to compile statistics about how our visitors collectively interact with our Website.

HOW WE COLLECT INFORMATION:

We collect information from various sources in three primary ways:

You Give Us Information: We collect information from you when you submit it to us through our Website, other digital media or in one of our stores.

We Collect Information Automatically: We automatically collect certain types of information when you visit our Website or use our products and services.  For example, we automatically collect various types of technical information when you use our Website as otherwise described in this Privacy Policy.

Use of Cookies:

Cookies are bits of electronic information that a website may transfer to a visitor’s computer to identify specific information about the visitor’s visits to the website.  We use cookies, for example, to preserve the contents of your virtual shopping bag between visits.  The Website uses a browser feature known as a cookie, which assigns a unique identification to your computer.  Cookies are typically stored on your computer’s hard drive and are used to help track clicks as you go through the pages within our Website. We may also use cookies to tell us whether you have previously visited the Website. We also use cookies that may be set by third-parties with whom we have entered into agreements, which may enable us to obtain analytics information about the use of our Website. 

You can set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. You may also use commonly available tools in your browser to remove cookies which may have been placed onto your computer. However, please be aware that the Website requires cookies to operate correctly. For example, if you turn off cookies or refuse them, you may not be able to make purchases on the Website.  

We will not use shared local objects (commonly referred to as “FLASH cookies”) in a manner inconsistent with the purposes for which they were designed unless you are specifically notified that we intend to use them for a specific service. FLASH cookies are cookies that are placed on your computer that are not removed through normal browser management tools.

Use of Web Beacons, Clear-GIFs, Pixel Tags and JavaScript:

We also may use “pixel tags” (also called “action pixels,” “web beacons” or “clear gifs”) and/or JavaScript plug-ins, placed on our Website and in our emails to you.  These web beacons and plug-ins are small graphic images (typically that you cannot see) or code on a website or in an email message which are used for such things as recording web pages and advertisements clicked-on by a user, or for tracking the performance of email marketing campaigns.  These devices help us analyze our customers’ online behavior and measure the effectiveness of our Website and our marketing.  We also work with third-party vendors that help us track, collect, and analyze this information.  Third-party entities with whom we have agreements may place these devices on the Website and/or in e-mails to use information obtained from them such as pages viewed, items purchased, e-mails opened and items upon which you may click in e-mails.  These third-party providers may also place cookies onto your computer.  Those third-party cookies may enable us to obtain aggregate demographic information and user statistics about you and your preferences from these third-party sources as well as our information we have about you.

Server Logs and Widgets:

A web “server log” is a record of activity created by a computer that delivers certain web pages to your browser.  Certain activities that you perform on our Website may record information in server logs, such as if you enter a search term into a search box located on the Website.  The server log may record the search term(s), or the link you clicked on to bring you to our Website.  The server log may also record information about your browser, such as your IP address and the cookies set on your browser.

A “widget” is generally an application that can be embedded in a webpage.  Widgets can provide real-time information to the webpage.  Widgets are often provided by third-parties and we may provide widgets on our Website.  Widgets may enable the third-parties that provide them to collect data about users visiting the Website.

Search Queries on Our Website:

We may provide you with options to search for information on our Website.  If you enter information in a search query box, we may store that information and we may aggregate that information with other information we may have about the browser and/or IP address from which the search query originated.

Surveys, Contests and Promotions:

From time to time, we may request information from users via surveys, contests and other promotions.  Participation in these surveys, contests or promotions is completely voluntary and the user therefore has a choice whether or not to disclose this information.  If you choose to participate, we may ask you for additional information, which may include contact information (such as name, email and shipping address) and/or demographic information (such as postal code, age level), to provide better services and options to you.  We use the information you provide to administer our contests, sweepstakes and other promotions, in addition to the purposes set forth herein. 

Content You Share

You may be able to post information and materials publicly, for example, in product reviews, chat areas, and other similar forums (collectively, “Forums”), subject to the Forum rules in our Terms of Use.  If you post any information in a Forum on the Website, it will be deemed public information and available to the general public.  Please do not post any personal information in a review or Forum.  If you do post personal information, you do so at your own risk, and consent to it being used as a submission, in accordance with our Terms of Use.

You may also be able to send certain content to other individuals using the Website.  To send information to others, we request both your email address and theirs.  We use this information only to fulfill your request.  We may retain the information you provide in connection with this feature.  We will not include any third-party advertisements within the messages sent to your friends.

HOW WE USE THE INFORMATION WE COLLECT:

We use the information we collect internally in our business for many business purposes, such as to:  (i) advance our economic and commercial interests by providing the products or services you may order, including processing orders and returns; (ii) analyze trends and conduct research about improving our products and services; (iii) maintain and service customer accounts; (iv) provide support and respond to questions from customers and Website visitors; (v) improve our stores, Website, products and/or services; (vi) audit customer activity in order to learn about and meet our customers’ needs; (vii) contact consumers for research, informational, and marketing purposes, including customizing our product recommendations and promotions to you based upon your information and purchases; (viii) track traffic patterns and Website usage; (ix) enable online ordering by processing and fulfilling your orders and transactions, processing payments, and providing customer service with respect to such orders; (x) correlate information with other commercially available information to identify demographics and preferences to assist us in our marketing efforts; (xi) provide specific relevant marketing, promotional, or other information to you; (xii) address information security and/or privacy practices control, network functioning, engineering, and troubleshooting issues; (xiii) ensure and improve the quality and safety of our services; (xiv) verify our customers information, and to protect against and prosecute those responsible for malicious, deceptive, fraudulent, or illegal activity; (xv) investigate and defend against claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process; (xvi) comply with law, or based on our good faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud to reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the Website or the public; and, (xvii) process or engage in a sale of all or part of our business, or if we go through a reorganization or merger.

We use the information we collect in a variety of ways.  Generally, using all of the above mentioned, and similar type tools, we may collect, aggregate, and use information from or about you such as data about the type of browser and operating system used, which web pages you view, the time and duration of your visits to our Website, the search queries you may use on this Website, whether you clicked on any items or links on the Website, whether you have clicked on any links in any emails sent from us, or third-parties on our behalf, whether you have chosen to opt-out of certain services or information sharing, and whether you have viewed or ordered certain products or services.

Finally, we may also use your personal information to contact you in ways other than e-mail or regular mail, such as via telephone contact, facsimile or SMS, in accordance with your communication preferences.

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose to the following categories of recipients:

CATEGORIES OF RECIPIENTS

CATEGORIES OF PERSONAL INFORMATION

Vendors who may need access to your personal information to help us provide our

e-Commerce service to you.

·     Identifiers;

·     Categories of personal information related to the California Customer Records statute (Cal. Civ. Code § 1798.80);

·     Commercial Information;

·     Internet or other Electronic Network Activity; and/or

·     Geolocation Data.

Payment processors, the issuing and acquiring banks involved in the funds settlement procedures necessary to charge your cards or financial accounts, entities who may provide financing for your purchase, and entities who provide identity and purchase verification to protect you and Paul Ropp from fraud.

·     Identifiers;

·     Categories of personal information related to the California Customer Records statute (Cal. Civ. Code § 1798.80);

·     Commercial Information;

·     Internet or other Electronic Network Activity; and/or

·     Geolocation Data.

Entities who provide labeling and shipping services to help us deliver the products you may order.

·     Identifiers;

·     Categories of personal information related to the California Customer Records statute (Cal. Civ. Code § 1798.80); and/or

·     Commercial Information.

Entities who provide us with e-mail address management, communication contact services, data aggregation services, and those who analyze and enhance our marketing campaigns.

·     Identifiers;

·     Categories of personal information related to the California Customer Records statute (Cal. Civ. Code § 1798.80);

·     Commercial Information;

·     Internet or other Electronic Network Activity;

·     Geolocation Data; and/or

·     Protected classification characteristics under California or federal law.

Judicial, administrative, legal, and/or financial accounting providers to help us review or release information in response to civil or criminal investigations, claims, lawsuits, or administrative requests, or to otherwise comply with our legal or regulatory obligations.

·     Identifiers;

·     Categories of personal information related to the California Customer Records statute (Cal. Civ. Code § 1798.80);

·     Commercial Information;

·     Internet or other Electronic Network Activity;

·     Audio, electronic and visual information;

·     Geolocation Data; and/or

·     Protected classification characteristics under California or federal law.

Governmental authorities, agencies or others pursuant to an order issued or authorized by a court of competent jurisdiction.

·     Audio, electronic and visual information, (i.e., in-store video monitoring)

Transfers of Personal Information During a Corporate Transaction

If Paul Ropp, or substantially all of its assets, were acquired, or in the unlikely event that Paul Ropp goes out of business or enters bankruptcy, Website user information (which may include any of the categories of personal information described in the What Information We Collect section of this Privacy Policy) 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 Paul Ropp may continue to use your personal information only in accordance with this Privacy Policy.

Sales of Personal Information

We do not sell your personal information as the term “sell” is commonly understood to require an exchange for money.

If you are a resident of California, please note that the California State Attorney General may issue guidance on whether the use of advertising and analytics cookies on our Website is considered a “sale” of personal information as the term “sale” is broadly defined in the California Consumer Privacy Act and its implementing regulations (the “CCPA”) to include both monetary and other valuable consideration.  Until such guidance has been issued, we continue to consider it a “sale” in order to be as transparent as possible with users of our Website and will comply with the restrictions of the “sale” of this information to the extent technologically feasible.

This “sale” would be limited to our use of analytics cookies and their use in understanding how consumers use and interact with our Website.

In the preceding 12 months, we have “sold” Internet or other electronic network activity information, as defined in the What Information We Collect section of this Privacy Policy, to internet cookie information recipients, such as analytics services.

YOUR CHOICES ABOUT THE INFORMATION WE COLLECT

If you do not consent to the way in which we may use your personal information, please do not submit any personal information to us.  If you do not wish to receive emails about special offers and other promotions from us, click the unsubscribe link located in our emails.  If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Policy, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be.  Please direct your opt-out request to:

online@paulropp.com or

Paul Ropp, Ltd

Attn: Director of Customer Service, Ecommerce

To learn more about interest-based advertising or to “opt-out” of interest based advertising programs from participating companies, visit www.networkadvertising.org/choices/ or www.aboutads.info/choices/.

California Consumer Privacy Act (CCPA) Consumer Rights

If you are a resident of California, the CCPA grants you the following specific rights regarding your personal information.  In order to exercise your rights, you must submit a consumer request, which must then be verified.  Generally, in order to verify your requests, we will compare the personal information we have about you to pieces of personal information we will request in the course of processing your request.  The personal information required for verification may include your name, email address, Loyalty membership number, phone number, shipping address, or the date of your last purchase from us.  We will deliver a response to you within 45 days of receiving the verifiable consumer request.

Right to Know

You have the right to submit a verifiable consumer request that we disclose the following to you in a readily useable format covering the 12-month period preceding your request:

The categories of personal information we have collected about you.

The categories of sources of the personal information we have collected about you.

The business or commercial purpose(s) for collecting personal information.

The categories of third parties with whom we share personal information.

The specific pieces of personal information we have collected about you.

The categories of personal information we have disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that particular category of personal information.

The categories of personal information we have sold, and for each category identified, the categories of third parties to whom we sold that particular category of personal information.

Verifiable consumer requests to know may be submitted through one of the following methods:

Submit a request via email at online@paulropp.com entitled “CCPA Request”; or

In-person at our retail locations.

A consumer may submit a request to know and receive a response twice within a 12-month period.

Right to Request Deletion

You have the right to request that we delete any personal information that we have collected from you.  However, we are not required to comply with a request to delete, if it is necessary for us to retain the personal information in order to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Debug products to identify and repair errors that impair existing intended functionality.

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

Comply with legal obligations.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Verifiable consumer requests to delete may be submitted through one of the following methods:

Submit a request via email at online@paulropp.com entitled “CCPA Request”; or

In-person at our retail locations.

Opt-Out and Opt-In Rights Regarding the “Sale” of Your Personal Information

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 and less than 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your Authorized Agent) may click the “Do Not Sell My Personal Information” link in the footer of our Website, email your request to opt-out to online@paulropp.com, or set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Website use all the features of our services. You can find more information about cookies at http://www.allaboutcookies.org.

Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into the sale of personal information at any time by adjusting your cookie preferences to accept all or certain cookies. (Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.)

Right to Non Discrimination

You have the right to be free from discrimination when you exercise your consumer rights under the CCPA, including by:

Denying you goods or services.

Charging you a different price or rate for goods or services, including through granting discounts or other benefits, or imposing penalties.

Providing you a different level of quality of goods or services.

Suggesting that you may receive a different rate for goods or services or a difference level or quality of goods or services.

Notice of Financial Incentive

Loyalty programs are only available to consumers on our Website and at select Paul Ropp store locations.

Loyalty Program

We offer consumers a loyalty program, that provides certain perks, such as discounts on purchases, shipping upgrades, sweepstakes entries and other benefits and rewards. When consumers sign up for our loyalty program, they may be required to provide personal identifiers, including their first and last name, email address, birthday, telephone number and zip code.  Consumers may cancel their participation in this program at any time by contacting our customer service team online@paulropp.com. Generally, we do not assign monetary or other value to personal information. However, California law requires that we assign such value in the context of financial incentives, such as our loyalty program. In such context, the value of a consumer’s personal information to us is related to the value of the discounted or free products or services or other benefits and rewards that the consumer obtains or that are provided to the consumer as part of the loyalty program, less the expense to us related to offering those products, services and benefits to the consumer as a participant in the program. The value may vary based on the amount the consumer purchases as a member of the program, the value of future offers that the consumer receives, and the extent to which the consumer uses those offers on future purchases from us. As an example, a 20% discount reward will vary in value to us depending on the products purchased by the consumer.

Authorized Agent

Under the CCPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf.  Should you choose to do so, for your and our protection, we will require you to verify your identity directly with us and directly confirm that you have provided the authorized agent permission to submit the request.  We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.

If you are visiting the Website from a location outside of the United States, your connection will be through servers located in the United States.  All information you receive from the Website will be created on servers located in the United States, and all information you provide will be maintained on web servers and systems located within the United States.  The data protection laws in the United States might not be the same as those in your country.  By using this Website and/or submitting information to us, you specifically consent to the transfer of your information to the United States to the facilities and servers we use, and to those with whom we may share your information.

UPDATING YOUR PERSONAL INFORMATION

We prefer to keep your personal information accurate and up-to-date.  If you would like to change your contact information, please login to your account.

LINKS