PRIVACY POLICY
LAST UPDATED 27/05/2022
Riverwood Furniture Ltd.(“Riverwood Furniture Ltd.”, “us”, “we” or “our”) is committed to protecting the
privacy and confidentiality of Personal Information we may collect. Riverwood Furniture Ltd. has created this privacy policy (“Privacy Policy”) to advise you about our
information practices, such as the types of information we collect and how we
may use that information, and to inform you about your privacy rights and how
the law protects you. We urge you to read this Privacy Policy carefully to
understand our policies and practices regarding your Personal Information and
how we will treat it. By visiting any part of our Websites (as defined below)
or otherwise providing Riverwood Furniture Ltd. with Personal Information by any means,
you accept and agree to the practices described in this Privacy Policy and your
continued use of the Websites (following the posting of a revised privacy
policy) means that you accept and agree to the terms of the revised privacy
policy, so please check the policy periodically for updates.
Individuals in the
European Union (“EU”) should be sure to read the important information provided
below, in addition to the other provisions in this Privacy Policy.
I. IMPORTANT
INFORMATION AND WHO WE ARE
II. THE INFORMATION WE
COLLECT ABOUT YOU
III. HOW IS YOUR
PERSONAL INFORMATION COLLECTED
IV. THIRD PARTY
INTERACTIONS
V. THIRD PARTY
ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING
VI. HOW WE USE YOUR
PERSONAL INFORMATION
VII. DISCLOSURES OF
YOUR PERSONAL INFORMATION
VIII. YOUR CHOICES
IX. DATA SECURITY
X. USERS OUTSIDE OF THE
UNITED KINGDOM AND INTERNATIONAL TRANSFERS
XI. QUESTIONS
XII. ADDITIONAL
INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION
I. IMPORTANT
INFORMATION AND WHO WE ARE
A. APPLICATION OF THIS
PRIVACY POLICY
This Privacy Policy
applies to www.riverwood-furniture.com and all other websites, features, or online
services that are owned or controlled by Riverwood Furniture Ltd. and that post a link
to this Privacy Policy (collectively, the “Websites”), whether accessed via
computer, mobile device, or otherwise. Note, however, this Privacy Policy does
not apply to use of unaffiliated websites that link to our Websites. Once you
enter another website (whether through an advertisement, service, or content
link), be aware that we are not responsible for the privacy practices of such
other websites.
B. PURPOSE OF THIS
PRIVACY POLICY
This Privacy Policy
aims to give you information on how Riverwood Furniture Ltd. collects and uses your
Personal Information through your use of the Websites, including any
information you may provide through the Websites when you sign up for an
account, sign up to receive information or communications from us, purchase a
product or service, or request further services or information from us.
It is important that
you read this Privacy Policy together with any other privacy notice or fair
processing notice we may provide on specific occasions when we are collecting
or using Personal Information about you so that you are fully aware of how and
why we are using your information. This Privacy Policy supplements the other
notices and is not intended to override them.
C. CHANGES TO THE
PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
This version was last
updated on February 8th, 2021 and historic versions can be obtained by
contacting us. We reserve the right, at any time and without notice, to add to,
change, update or modify this Privacy Policy, simply by posting such change,
update or modification on the Websites. Any such change, update or modification
will be effective immediately upon posting on the Websites. However, unless you
consent, Riverwood Furniture Ltd. will not use your Personal Information in a manner
materially different than what was stated in our posted Privacy Policy at the
time your Personal Information was collected. Please check this Privacy Policy
regularly to ensure you are aware of any changes in our practices.
It is important that
the Personal Information we hold about you is accurate and current. Please keep
us informed if your Personal Information changes during your relationship with
us. You are responsible for maintaining the accuracy of the information you
submit to us, such as your contact information. If you contact us with changes,
we will make good faith efforts to make requested changes in our then-active
databases as soon as reasonably practicable. Note, however, that information
may persist internally for our administrative purposes and that residual data
may remain on backup media or for other reasons.
D. THIRD PARTY CONTENT,
LINKS TO OTHER WEBSITES, AND Riverwood Furniture Ltd. CONTENT FOUND OUTSIDE THE
WEBSITES
The Websites may
include links to third-party websites, plug-ins and applications and certain
content on the Websites may be hosted and served by third parties that Riverwood Furniture Ltd. does not control. When you click on a link to any other website or
location, you will leave our Websites and go to another site and another entity
may collect Personal Information from you. We have no control over, do not
review, and cannot be responsible for, these outside websites or their content.
Please be aware that the terms of this Privacy Policy do not apply to these
outside websites, their privacy statements or content, or to any collection of
your Personal Information after you click on links to such outside websites. We
encourage you to read the privacy policies of every website you visit. The
links to third party websites or locations are for your convenience and do not
signify our endorsement of such third parties or their products, content or
websites. In addition, Riverwood Furniture Ltd. content may be included on web pages
and websites that are not associated with Riverwood Furniture Ltd. and over which we
have no control. These third parties may collect data through the use of their
own cookies, pixel tags or other technology, independently collect information
or solicit Personal Information, and may have the ability to track your use of
their websites and services. Riverwood Furniture Ltd. is not responsible for the
privacy practices or the content of any third party.
II. THE INFORMATION WE
COLLECT ABOUT YOU
Personal Information or
personal data means any information about an individual from which that person
can be identified. It does not include information where the identity has been
removed (anonymous data). We and our third-party service providers may collect,
use, store and transfer different kinds of Personal Information about you that
we have grouped together as follows:
● IDENTITY INFORMATION
includes name, username or similar identifier, title, date of birth, and
gender.
● DEMOGRAPHIC
INFORMATION includes zip code, age and/or income.
● CONTACT INFORMATION
includes billing address, delivery address, email address and telephone
numbers.
● FINANCIAL INFORMATION
includes bank account and payment card details (applicable if any payments were
made).
● TRANSACTION
INFORMATION includes details about payments to and from you and other details
of services you have purchased from us (applicable if any payments has been
made).
● TECHNICAL INFORMATION
includes internet protocol (IP) address, your login data, browser type and
version, time zone setting and geographical location, browser plug-in types and
versions, operating system and platform and other technology or other unique
identifier (a set of numbers or characters that is assigned to your computer,
mobile phone, or other device when you are on the Internet) (“Device
Identifier”) for any computer, mobile phone, tablet or other device (any of
which are referred to herein as a “Device”) used to access the Websites.
● PROFILE INFORMATION
includes your username and password, purchases or orders made by you
(applicable if any orders were made), your interests, preferences, product
feedback, and survey responses.
● USAGE DATA includes
information about how you use our Websites, products and services, including
all of the areas within our Websites that you visit or use and the time of day
you visited the Websites, among other information.
● MARKETING AND
COMMUNICATIONS INFORMATION includes your preferences in receiving marketing
from us and our third parties and your communication preferences.
● LOCATION INFORMATION
includes information about your location using a variety of technologies, such
as GPS, IP address, and connected or nearby Wi-Fi networks.
● USER CONTENT
INFORMATION includes text (including questions, comments, and suggestions),
pictures, audio, videos, or other content (collectively, "User
Content") you share by participating and posting content publicly in
reviews, interactive features, or other communication functionality (“Community
Features”).
We also collect, use
and share AGGREGATED INFORMATION such as statistical or demographic information
for any purpose. Aggregated Information may be derived from your Personal
Information but is not considered Personal Information in law as this
information does not directly or indirectly reveal your identity. For example,
we may aggregate your Usage Data to calculate the percentage of users accessing
a specific website feature. However, if we combine or connect Aggregated
Information with your Personal Information so that it can directly or
indirectly identify you, we treat the combined information as Personal
Information that will be used in accordance with this Privacy Policy. We do not
collect any SPECIAL CATEGORIES of Personal Information about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex
life, sexual orientation, political opinions, trade union membership,
information about your health and genetic and biometric data). Nor do we
collect any information about criminal convictions and offences.
III. HOW WE COLLECT
YOUR PERSONAL INFORMATION
We use different
methods to collect information from and about you including through:
● DIRECT INTERACTIONS.
You may give us your Identity, Demographic, Contact, Financial, Profile, or
Marketing and Communications Information by filling in forms or by
corresponding with us by mail, phone, email, or otherwise. This includes
Personal Information you provide when you:
● purchase our products
or services;
● create an account on
our Websites;
● subscribe to emails
or newsletters;
● request services or
other information;
● enter a competition,
promotion or survey; or
● give us feedback
about products, services, or the Websites.
● AUTOMATED
TECHNOLOGIES OR INTERACTIONS.
As you navigate through
the Websites, we may automatically collect Technical, Usage, and Location
Information about your equipment, browsing actions and patterns. We collect
this Personal Information by using cookies, pixel tags, embedded scripts and
other similar technologies. [We may also receive Technical Information about
you if you visit other websites employing our cookies.]
● COOKIES - Cookies are
small data files that a website sends to your Device while you are viewing the
website that are stored on the Device. Cookies can be used for many purposes,
including to monitor use of websites, to customize content specific to your
interests, to ensure that you do not see the same advertisement repeatedly, to
speed up your searches and purchases and to recognize you when you return to
our Websites and/or store your user name and password so you do not have to
re-enter it each time you visit the Websites. You may refuse to accept cookies
by activating the appropriate setting on your browser. However, if you choose
to disable cookies on your Device, some features of the Websites or our content
may not function properly.
● PIXEL TAG – Pixel
Tags (also referred to as clear GIFs, 1x1 GIFs Web beacons, or Web bugs) are
small graphic images or other web programming code that may be included on the
Websites and in our e-mail messages. In contrast to Cookies, which are stored
on a user’s Device, Pixel Tags are embedded invisibly in web pages. Pixel Tags
may be invisible to you, but any electronic image or other web programming code
inserted into a web page or e-mail can act as a pixel tag. Pixel Tags or
similar technologies may be used for a number of purposes, including, without
limitation, to count visitors to the Websites, to monitor how users navigate
the Websites, to count how many e-mails that were sent were actually opened or
to count how many particular articles or links were actually viewed.
● EMBEDDED SCRIPTS -
Embedded scripts are programming code designed to collect information about
your interactions with the Websites, such as the links you click. The code is
temporarily downloaded onto your Device from our web server or a third party
service provider, and is active only while you are connected to the Websites.
● FLASH LSOS – When we
post videos, third parties may use local shared objects, known as “flash
cookies,” to store your preferences for volume control or to personalize
certain video features. Flash Cookies are different from browser Cookies
because of the amount and type of data and how the data is stored. Cookie
management tools provided by your browser will not remove Flash Cookies. To
learn how to manage privacy and storage settings for Flash Cookies, please
visit:
HTTP://WWW.MACROMEDIA.COM/SUPPORT/DOCUMENTATION/EN/FLASHPLAYER/HE
LP/SETTINGS_MANAGER07.HTML.
● COMMUNITY FEATURES.
The Websites may provide you the opportunity to participate and post User
Content publicly through reviews, surveys, interactive features, or other
communication functionality (“Community Features”). We may provide
functionality for you to submit or post User Content through Community
Features, by linking the Websites to a third party service, or otherwise.
Please note that certain information, such as your name, may be publicly displayed
on the Websites along with your User Content. User Content consisting of
uploaded files may contain metadata, which may contain Personal Information or
other information about or relating to you. You may wish to remove metadata
from your files before transmitting such files to Riverwood Furniture Ltd. . NOTE THAT
ANYTHING YOU POST THROUGH COMMUNITY FEATURES IS PUBLIC – OTHERS WILL HAVE
ACCESS TO YOUR USER CONTENT AND MAY USE IT OR SHARE IT WITH THIRD PARTIES. IF
YOU CHOOSE TO VOLUNTARILY DISCLOSE PERSONAL INFORMATION, THAT INFORMATION WILL
BE CONSIDERED PUBLIC INFORMATION AND THE PROTECTIONS OF THIS PRIVACY POLICY
WILL NOT APPLY. IF YOU SUBMIT USER CONTENT, IT MAY BE PUBLISHED ONLINE OR
OFFLINE AT ANY TIME. IN ADDITION, WE MAY USE YOUR USER CONTENT AND ANY EXCERPT
FROM YOUR USER CONTENT IN CONNECTION WITH OUR ADVERTISING, MARKETING, PUBLICITY
AND PROMOTIONAL ACTIVITIES.
● THIRD PARTIES OR
PUBLICLY AVAILABLE SOURCES. We may receive Personal Information about you from
various third parties. For example, if you are on another website and you
opt-in to receive information from us, the other website will forward your
Contact Information and other information to us so that we may contact you as
requested. We also may supplement the information we collect with outside
records from third parties in order to provide you with information, services
or goods you have requested, to enhance our ability to serve you, and to tailor
our content to you. We may combine the information we receive from those other
sources with information we collect through the Websites. In those cases, we
will apply this Privacy Policy to the combined information. Examples of third
party sources include:
● Technical Information
from the following parties: ○ analytics providers; ○ advertising networks; and
○ search information.
● Contact, Financial
and Transaction Information from providers of technical, payment and delivery
services.
● Identity and Contact
Information from publicly available sources.
● INFORMATION PROVIDED
FROM OTHER USERS. If you decide to invite a third party to create an account
and/or purchase our merchandise, we will collect the Identity and Contact
Information you provide (e.g., name and e-mail address) for you and the third
party in order to send a message to the third party and follow up with the
third party. We rely upon you to obtain whatever consents from the third party
that may be required by law to allow us to collect such information and contact
the third party as described in the foregoing sentence. You or the third party
may contact us at admin@riverwood-furniture.com to request the removal of this
information from our database.
IV. THIRD PARTY
INTERACTIONS
Certain functionality
on the Websites may permit interactions that you initiate between the Websites
and a third party website or service (“THIRD PARTY INTERACTIONS”). Examples of
Third Party Interactions may include technology that enables you to “like” or
“share” content from the Websites on or to other websites or services; to
transmit content to the Websites from your account on a third party website or
service; to otherwise connect the Websites to a third party website or service,
such as through an application programming interface (API) made available by
Riverwood Furniture Ltd. or a third party; or for users to register for an account and
login through social networking sites such as Facebook and Google (each an
“SNS”). By registering or logging in through a SNS, you are allowing the
Websites to access your information and you are agreeing to the SNS’s Terms of
Use and Privacy Policy in your use of such services. We may receive information
from the SNS to make it easier for you to create an account with us. Any
information that we collect from your SNS account may depend on the privacy
settings you have with that SNS, so please consult the SNS’s privacy and data
practices.
If you choose to use
Third Party Interactions, information you post or provide access to may be
publicly displayed on the Websites or by the provider of the Social Feature
that you use. Similarly, if you post information on a third party platform that
references the Websites (e.g., by mentioning one of the Websites or using a
hashtag associated with one of the Websites in a tweet or status update), your
post may be published on our Websites in accordance with the terms of the third
party website or service. Also, both Riverwood Furniture Ltd. and the third party may
have access to certain information about you and your use of the Websites and
the third party website or service. In addition, we may receive information about
you in connection with other users’ use of Third Party Interactions (e.g., we
may learn that you are a “friend” or “connection” of the third party or receive
other information about you that the other user enables us to receive). The
information we collect in connection with Third Party Interactions is subject
to this Privacy Policy.
The information
collected and stored by the third party remains subject to the third party’s
privacy practices, including whether the third party continues to share information
with us, the types of information shared, and your choices with regard to what
is visible to others on that third party website or service.
V. THIRD PARTY
ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING
Riverwood Furniture Ltd. works with certain third parties
(including network advertisers, ad agencies, and analytics companies) to
provide us with information regarding traffic on the Websites, to serve
advertisements, including our advertisements elsewhere online, and to provide
us with information regarding the use of the Websites and the effectiveness of
our advertisements.
These third parties may
use Device Identifier and Usage Data to compile reports on user activity. For
example, if you clicked on one of our advertisements that led you to one of the
Websites, our service provider(s) may be able to tell us which advertisement
you clicked on and where you were viewing the advertisement. These third
parties may set and access their own tracking technologies (including cookies,
embedded scripts, and pixel tags) and may otherwise collect or have access to
your Device Identifier, Usage Data and related information about you. Cookies
and pixel tags, including those set by third party network advertisers, may be
used to, among other things, target advertisements, prevent you from seeing the
same advertisements too many times, conduct research regarding the usefulness
of certain advertisements to you, and assist in providing analytics. These
third parties may also transfer Device Identifier and Usage Data to other third
parties where required to do so by law, or where such third parties process
analytics information on their behalf. Each of these third party’s ability to
use and share Device Identifier and Usage Data is restricted by their
respective Terms of Use and Privacy Policy. By using our Websites, you consent
to the processing of data about you by these third parties in the manner and
for the purposes set out above. For a full list of third party analytics
services, please contact us at admin@riverwood-furniture.com.
We may share Device
Identifier and Usage Data about visitors with third party advertising
companies, analytics providers and other vendors for similar purposes. While we
may use a variety of service providers to perform advertising and analytics
services, some of these companies may be members of the Network Advertising
Initiative ("NAI”) or the Digital Advertising Alliance ("DAA")
Self-Regulatory Program for Online Behavioral Advertising.
For additional
information regarding targeted advertising and the “opt-out” procedures of NAI
members and DAA Self-Regulatory Program participating companies, you may visit:
● NAI Opt-Out Tool (for
website users):
http://www.networkadvertising.org/managing/opt_out.asp
● DAA Consumer Choice
(for website users): http://www.aboutads.info/choices/
● DAA AppChoices (for
mobile app users): http://youradchoices.com/appchoices
Please note that opting
out through these mechanisms does not opt you out of being served advertising.
You will continue to receive generic ads while visiting the Websites and
elsewhere online. Some third parties may collect Personal Information about
your online activities over time and across different websites.
Your browser settings
may allow you to automatically transmit a “Do Not Track” signal to websites and
online services you visit. However, there is no consensus among industry
participants as to what “Do Not Track” means in this context. Like many
websites and online services, the Websites currently do not respond to or alter
their practices when they receive a “Do Not Track” signal from a visitor’s
browser. To find out more about “Do Not Track,” you may wish to visit
http://www.allaboutdnt.com.
VI. HOW WE USE YOUR
PERSONAL INFORMATION
We may use the
information we collect about you, including Personal Information and Usage
Data:
● to provide you with
our products and services and related customer service;
● to process your
registration and account creation with the Websites, including verifying your
contact information is active and valid;
● to identify you as a
user in our system;
● to provide you with
information, products or services that you have requested or agreed to receive;
● to provide improved
administration of our Websites and services;
● (if applicable) to
process transactions you initiate, process payments and provide accurate
billing and shipping;
● (if applicable) to
send you administrative e-mail notifications, such as order confirmations,
order status updates, security, or support and maintenance advisories;
● (if applicable) to
bill you for Riverwood Furniture Ltd. products or services;
● respond to your
inquiries related to employment opportunities or other requests;
● send newsletters,
surveys, offers, and other promotional materials related to our services and
for other marketing purposes of Riverwood Furniture Ltd.;
● to market our
products/ services, including recommending products / services that might be of
interest to you;
● to improve our
Websites, product and service offerings;
● to present our
Websites and its contents in a suitable and effective manner for you and for
your computer;
● to customize and
tailor your experience on the Websites, for example, by displaying content that
we think you might be interested in;
● to improve the
quality of experience when you interact with our Site and Services for internal
business purposes;
● for compliance fraud
prevention and safety, including enforcing our terms of service and this
Privacy Policy, protecting our rights privacy, safety, or property and/or that
of you or others, and protecting against, investigating or deterring
fraudulent, harmful, unauthorized, unethical or illegal activity;
● to carry out our
obligations and enforce our rights arising from any contracts entered into
between you and us;
● to notify you about
changes to our service;
● to comply with
applicable laws, lawful requests, and legal process, such as to respond to
subpoenas or requests from government authorities;
● to contact you with
regard to your use of the Websites and, in our discretion, changes to the
Websites policies or functionality; and
● to perform other
functions as described at the time of collection, with your consent, or as
further described in this Privacy Policy. In addition to the above, we may use
anonymous data to analyze request and usage patterns so that we may enhance the
content of our services and improve navigation on the Websites.We reserve the
right to use anonymous data for any purpose and disclose anonymous data to
third parties in our sole discretion.
A.EMAIL COMMUNICATIONS
We may use your Identity,
Contact, Technical, Usage and Profile Information to form a view on what we
think you may want or need, or what may be of interest to you. This is how we
decide which products, services and offers may be relevant for you.You will
receive newsletters or marketing communications from us if you have requested
information from, purchased goods or services from us, or if you provided us
with your details when you entered a competition or registered for a promotion
and, in each case, you have consented receiving marketing communications at
that time.
B.COOKIES
A cookie is a data file
containing an identifier (a string of letters and numbers) that is sent by a
web server to a web browser and is stored by the browser. The identifier is
then sent back to the server each time the browser requests a page from the
server. Cookies may be either “persistent” cookies or “session” cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session,
when the web browser is closed. Cookies do not typically contain any
information that personally identifies a user, but Personal Information that we
store about you may be linked to the information stored in and obtained from
cookies.
We may use both session
cookies and persistent cookies to provide you with a more personal and
interactive experience on our Site. This type of information is collected to
make the Websites more useful to you and to tailor the experience with us to
meet your special interests and needs.
Most browsers allow you
to refuse to accept cookies and to delete cookies. The methods for doing so
vary from browser to browser, and from version to version. You can however
obtain information about blocking and deleting cookies for some commonly used
browsers via the links below:
● CHROME:
https://support.google.com/chrome/answer/95647?hl=en;
● EDGE:
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy;
● FIREFOX:
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;
● INTERNET EXPLORER:
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
● OPERA:
http://www.opera.com/help/tutorials/security/cookies/; and
● SAFARI:
https://support.apple.com/kb/PH21411.
Please note that
blocking all cookies will have a negative impact upon the usability of many
websites and if you choose to block cookies, you may not be able to use all the
features on our Websites.
VII. DISCLOSURES OF
YOUR PERSONAL INFORMATION
We may share
non-personally identifiable information, such as aggregated user statistics, in
our discretion and without restriction. We may disclose the information we have
collected about you, including Personal Information, as disclosed at the time
you provide your information, with your consent, as described in this Privacy
Policy, or in the following circumstances:
A. INTERNAL THIRD
PARTIES
Riverwood Furniture Ltd. may, and reserves the right
to, share your information with any other company that is not presently, but
becomes, a Riverwood Furniture Ltd. parent, subsidiary, or affiliate. You may be
presented with an opportunity to receive information and/or marketing offers
from Riverwood Furniture Ltd. and our affiliated businesses, partners and agents. If
you agree at that time to receive such communications, your Personal
Information will be disclosed to that third party (or parties). For more
information, please refer to the Marketing Communications section.
B. EXTERNAL THIRD
PARTIES
Third Party Service
Providers
We may share personal
information with third party service providers in connection with the
performance of services to, or on behalf of, Riverwood Furniture Ltd. and the Websites,
including to conduct quality assurance testing; to facilitate creation of
accounts; to provide technical support; and/or to provide other services to
Riverwood Furniture Ltd.. You acknowledge and agree that your use of the Websites may
include having your Personal Information transferred to and stored by our web
hosting company pursuant to their privacy policy.
We may also share
Information when we work with businesses, partners or agents to develop a
direct relationship with you or in connection with the Referral Program.
These service providers
may store or use your information outside of the EU or United States.
Administrative &
Legal Reasons
We may transfer and
disclose information, including Personal Information, to third parties:
● to comply with a
valid legal inquiry, investigation, or process such as a search warrant,
subpoena, statute or court order, or if in our opinion such disclosure is
required by law;
● to obtain or maintain
insurance coverage, manage risks, obtain professional advice, or establish,
exercise or defend legal claims, whether in court proceedings or in an
administrative or out-of-court procedure;
● to protect the
safety, interests, rights, property or security of Riverwood Furniture Ltd., you, or
any third party; this may include exchanging information with other companies
and organizations for the purposes of fraud protection and credit risk
reduction;
● to respond to a
breach or attempted breach of the security of our Websites;
● to defend or assert
our legal rights pursuant to any of the Websites’ Terms of Use, any policies
applicable to the Websites, or any other agreement you may have with Riverwood Furniture Ltd.;
or
● at the request of
governmental authorities conducting an investigation.
We may also use
Technical Information to identify users, and may do so in cooperation with
copyright owners, Internet service providers, wireless service providers, or
law enforcement agencies in our discretion.
Social Networking Sites
As set forth in Section
IV, our Websites and services enable you to post content to SNSs. If you choose
to do this, we will provide information to such SNSs in accordance with your
elections. You acknowledge and agree that you are solely responsible for your
use of those websites and that it is your responsibility to review the terms of
use and privacy policy of the applicable SNS. We will not be responsible or
liable for: (i) the availability or accuracy of such SNSs; (ii) the content,
products or services on or availability of such SNSs; or (iii) your use of any
such SNSs.
Community Features
As set forth in Section
III, our Websites and services enable you to post User Content through
Community Features. If you choose to use these features, you will be identified
by your first name and last initial. Please note that any Personal Information
you include on a public area of the Site will be publicly viewable. Once
displayed publicly, that information can be collected and used by others. We
cannot control who reads your postings or what other users may do with the
information that you voluntarily post, so it is very important that you do not
put data such as private contact information that you do not want to make
available to the public in your posts. Once you have posted information
publicly, while you will still be able to edit and delete it on the Site, you
will not be able to edit or delete such information cached, collected, and
stored elsewhere by others (e.g., search engines).
We require all third
parties to respect the security of your Personal Information and to provide the
same level of privacy protection as required by this Privacy Policy.
C. SHARING BETWEEN
Riverwood Furniture Ltd. COMPANIES; BUSINESS TRANSFERS
Riverwood Furniture Ltd. may
also disclose and transfer your Personal Information: (i) to a subsequent
owner, co-owner or operator of the Websites or applicable database, or of our
products or services; (ii) if Riverwood Furniture Ltd. (or any of its affiliated,
parent, or subsidiary companies) assigns its rights regarding any of your
information to a third party; or (iii) in connection with or during negotiation
of a corporate merger, financing consolidation, restructuring, the acquisition
or dissolution transaction or proceeding involving sale, transfer, divestiture,
or disclosure of all or a portion of our business or assets including, without
limitation, during the course of any due diligence process. In the event of an
insolvency, bankruptcy, or receivership, Personal Information may also be
transferred as a business asset. If another company acquires our company,
business, or assets, that company will possess the Personal information
collected by us and will assume the rights and obligations regarding your
Personal information as described in this Privacy Policy. These transfers and
disclosures may be carried out without notice to you.
VIII. YOUR CHOICES
You have several
choices regarding the use of information on our Websites and services:
A. ACCESSING, UPDATING,
CORRECTING OR DELETING INFORMATION
You can review, request
access to, update, correct or delete your Personal Information by contacting us
at admin@riverwood-furniture.com.
You may request
deletion of your Personal information by contacting us and we will use
commercially reasonable efforts to honor your request, but please note that we
may be required to keep such information and not delete it (or to keep this
information for a certain time, in which case we will comply with your deletion
request only after we have fulfilled such requirements). When we delete any
information, it will be deleted from the active database, but may remain in our
archives. We may also retain information for fraud prevention or similar
purposes. Also, note that we may need to delete your user account in order to
delete your Personal Information.
You are responsible for
maintaining the accuracy of the information you submit to us, such as your
contact information. If you contact us with changes, we will make good faith
efforts to make requested changes in our then-active databases as soon as
reasonably practicable. Note, however, that information may persist internally
for our administrative purposes and that residual data may remain on backup
media or for other reasons.
B. OPTING OUT
We will only send you
direct marketing emails or other similar communications if you opt-in to
receive such emails. In the future, if you do not wish to have your e-mail
address or other contact information used for promotional purposes, you may
indicate a preference to stop receiving further communications from us and can
“opt-out” by following the unsubscribe instructions provided in the e-mail you
receive or by contacting us directly (please see contact information in Section
A above). Where you opt out of receiving these marketing messages, this will
not apply to Personal Information provided to us as a result of the purchase of
any service or other transaction and we may send you service related
communications, including notices of any updates to our Terms of Use or Privacy
Policy.
C. CHOOSING NOT TO
SHARE PERSONAL INFORMATION
You may choose not to
provide us with any Personal Information. In such an event, you may still be
able to access and use some of the Websites; however you may not be able to
access and use those portions of the Websites that require your Personal
Information. You may opt out of receiving marketing e-mails by following the
opt-out instructions above or provided to you in those e-mails. Please note
that we reserve the right to send you certain communications relating to your
account or use of any of the Websites (for example, administrative and service
announcements, shipping notices, and order confirmations) and these
transactional account messages may be unaffected if you opt-out from marketing
communications.
Where we need to
collect Personal Information by law, or under the terms of a contract we have
with you and you fail to provide that information when requested, we may not be
able to perform the contract we have or are trying to enter into with you (for
example, to provide you with goods or services). In this case, we may have to
cancel a product or service you have with us but we will notify you if this is
the case at the time.
D. MARKETING
COMMUNICATIONS
We strive to provide
you with choices regarding certain Personal Information uses, particularly
around marketing and advertising. You can opt-out of such communications as
outlined in Section B, above Please note that you may continue to receive
service-related and other non-marketing communications.
E. DE-LINKING THIRD
PARTY INTERACTIONS AND SNS
As set forth in Section
IV, our Websites and services enable you to interact with or post content to
certain third parties and SNSs. If you would like to discontinue these
interactions and connections, please refer to the privacy settings of the third
party or SNS to determine how you may adjust our permissions and manage the
interactivity between the Services and your social media account.
IX. DATA SECURITY
Riverwood Furniture Ltd. uses
commercially reasonable security measures to safeguard the Personal Information
we collect from loss, misuse and unauthorized access, disclosure, alteration
and destruction. However, please note that no system can be completely secure
and Riverwood Furniture Ltd. does not ensure or warrant the security of any information
we collect. You use our Websites and provide us with your information at your
own risk.
We have put in place
procedures to deal with any suspected Personal Information breach and will
notify you and any applicable regulator of a breach where we are legally
required to do so.
X. USERS OUTSIDE OF THE
UNITED KINGDOM AND INTERNATIONAL TRANSFERS
The Websites are hosted
and operated in the United Kingdom and third party service providers and
partners operate in the United Kingdom and other jurisdictions. If you are
located outside of the United Kingdom, please be aware that any information you
provide to us may be transferred to and processed in the United Kingdom and
other countries. By using the Websites, or providing us with any information,
you acknowledge and consent to this transfer, processing and storage of your information
in countries where the privacy laws may be less stringent than those in the
country where you reside or are a citizen.
XI. QUESTIONS
If you have any
questions or concerns regarding our privacy policy or practices, please feel
free to contact us via email at admin@riverwood-furniture.com.
XII. ADDITIONAL
INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION
A. PERSONAL INFORMATION
References to “Personal
Information” in this Privacy Policy are equivalent to “Personal Data” governed
by European data protection legislation.
B. LEGAL BASES FOR
PROCESSING PERSONAL DATA
We will only use your
personal data when the law allows us to do so. Most commonly, we will use your
Personal Information in the following circumstances:
● Where we need to
perform obligations relating to a contract to which you are a party or to take
steps at your request before entering into such a contract.
● Where it is necessary
for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests. Our legitimate interests
include those related to conducting and managing our business to enable us to
give you the best service/product and the best and most secure experience. We
make sure we consider and balance any potential impact on you (both positive
and negative) and your rights before we process your Personal Information for
our legitimate interests. We do not use your Personal Information for
activities where our interests are overridden by the impact on you (unless we
have your consent or are otherwise required or permitted to by law). You can
obtain further information about how we assess our legitimate interests against
any potential impact on you in respect of specific activities by contacting us.
● Where we need to
comply with a legal or regulatory obligation.
Generally, we do not
rely on consent as a legal basis for processing your Personal Information other
than in relation to sending marketing communications to you via email. You have
the right to withdraw consent to marketing at any time by contacting us using
the contact information provided above.
We have set out below,
in a table format, a description of the ways we plan to use your personal data,
and which of the legal bases we rely on to do so. We have also identified what
our legitimate interests are where appropriate. Note that we may process your
personal data for more than one lawful ground depending on the specific purpose
for which we are using your data. Please contact us if you need details about
the specific legal ground we are relying on to process your personal data.
C. CONTROLLER
This Privacy Policy is
issued on behalf of admin@riverwood-furniture.com
If you have any
questions about this Privacy Policy, including any requests to exercise your
legal rights, please contact us using the details set out below.
D. DATA RETENTION
We will only retain
your personal data for as long as necessary to fulfil the purposes we collected
it for, including for the purposes of satisfying any legal, accounting, or
reporting requirements.
To determine the
appropriate retention period for personal data, we consider the amount, nature,
and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through
other means, and the applicable legal requirements.
In some circumstances,
you can ask us to delete your data: see the Request Erasure subsection below
for further information.
In some circumstances
we may anonymise your personal data (so that it can no longer be associated
with you) for research or statistical purposes in which case we may use this
information indefinitely without further notice to you.
E. CHANGE OF PURPOSE
We will only use your
personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is
compatible with the original purpose. If you wish to get an explanation as to
how the processing for the new purpose is compatible with the original purpose,
please contact us. If we need to use your personal data for an unrelated
purpose, we will notify you and we will explain the legal basis that allows us
to do so.
Please note that we may
process your personal data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.
F. EU RESIDENT PERSONAL
DATA RIGHTS
Under certain
circumstances, EU Residents may have rights under data protection laws in
relation to your personal data as outlined below:
● REQUEST ACCESS to
your personal data (commonly known as a “data subject access request”). This
enables you to receive a copy of the personal data we hold about you and to
check that we are lawfully processing it.
● REQUEST CORRECTION of
the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need
to verify the accuracy of the new data you provide to us.
● REQUEST ERASURE of
your personal data. This enables you to ask us to delete or remove personal
data where there is no good reason for us continuing to process it. You also
have the right to ask us to delete or remove your personal data where you have
successfully exercised your right to object to processing (see below), where we
may have processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however, that we may
not always be able to comply with your request of erasure for specific legal
reasons that will be notified to you, if applicable, at the time of your
request.
● OBJECT TO PROCESSING
of your personal data where we are relying on a legitimate interest (or those
of a third party) and there is something about your particular situation that
makes you want to object to processing on this ground as you feel it affects
your fundamental rights and freedoms. You also have the right to object where
we are processing your personal data for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds to process
your information that override your rights and freedoms.
● REQUEST RESTRICTION
OF PROCESSING of your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios: (a) if you want us
to establish the data’s accuracy; (b) where our use of the data is unlawful but
you do not want us to erase it; (c) where you need us to hold the data even if
we no longer require it as you need it to establish, exercise or defend legal
claims; or (d) you have objected to our use of your data but we need to verify
whether we have overriding legitimate grounds to use it.
● REQUEST THE TRANSFER
of your personal data to you or to a third party. We will provide to you, or a
third party you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated
information which you initially provided consent for us to use or where we used
the information to perform a contract with you.
● WITHDRAW CONSENT at
any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out
before you withdraw your consent. If you withdraw your consent, we may not be
able to provide certain products or services to you. We will advise you if this
is the case at the time you withdraw your consent.
If you wish to exercise
any of the rights set out above, please contact admin@riverwood-furniture.com.
No Fee Usually Required
You will not have to
pay a fee to access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we may refuse to comply with
your request in these circumstances.
What We May Need From
You
We may need to request
specific information from you to help us confirm your identity and ensure your
right to access your personal data (or to exercise any of your other rights).
This is a security measure to ensure that personal data is not disclosed to any
person who has no right to receive it. We may also contact you to ask you for
further information in relation to your request to speed up our response.
Time Limit To Respond
We try to respond to
all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number
of requests. In this case, we will notify you and keep you updated.
Complaints to
Supervisory Authority
EU Residents may have
the right to make a complaint at any time to the supervisory authority for data
protection issues. However, we would appreciate the chance to deal with your concerns
before you approach the supervisory authority so please first contact us
directly to allow us to do so.