1.2 ABS is the data controller of your personal data. You can contact us by mail at the above address, by email at customercare@abs.com or by telephone at (626) 271-1580. References in thisprivacy policy to “we”, “us” and “our” are to ABS.
2.1 This privacy policy tells you about how we use, protect and disclose your personal data that we have collected using both offline means (e.g. via phone, post, in-person meetings and other correspondence) and online means, such as when you use the ABS.com website and our programs and services (collectively, the “Site”).
2.2 You acknowledge that your personal data (including personal data collected through your use of our services, and the Site), will be collected, stored, shared and processed in accordance with this privacy policy.
2.3 The Site may contain links to other third-party websites or applications. Please be aware that these websites and applications may collect information about you. These websites and applications may have their own privacy notices or policies. We encourage you to be aware when you leave the Site and to read the privacy statements of each and every website and application that you use.
2.4 To the extent any linked websites or applications you visit are not owned or operated by ABS, please be aware that we are not responsible or liable for the websites’ or applications’ content, any use of the websites or applications, or the privacy and security practices and policies of those websites or applications.
3.1 We may collect the following data about you. Please note that we may combine personal data collected about you from one source with personal data that we have collected about you from other sources.
(a) Personal data provided voluntarily including interactions(e.g. reviews, feedback, comments, testimonials)
We collect personal data that you, or an individual authorized to act on behalf of you (the “Representative”), voluntarily provides to us. We also collect personal data you provide to us when you post a testimonial, feedback, review or comment on the Site. This personal data may include your name and contact information, photos that you choose to upload and other personal data you may choose to provide as part of your post. We do not access photos on your device or cameras unless you allow us to do so. If you do allow us, you can manage your photos and camera settings at any time by changing the settings on your mobile device.
Please note that personal data that you choose to post in a testimonial, feedback, review or comment may be read, collected and used by anyone. Therefore, please do not post anything you do not wish to be accessed by others.
(b) Correspondence
We collect personal data where you contact us or we contact you, and we will typically keep a record of such correspondence. This personal data may include your name and contact information, account information, your order information, your queries, and other personal data you may choose to provide to us.
(c) Information stored on a Device
We may access metadata and other information associated with other files stored on your computer, tablet, mobile phone, or any other device (referred to collectively as a “Device”) such as IP address, domain name, browser version and operating system, traffic data, web logs and other communication data, and device identifiers. We may also collect photos, videos, Touch ID and Face ID login abilities and session IDs for third party service providers such as payment providers (“Device Information”). To the extent required by applicable law, we will ask for your consent prior to collecting Device Information. Please note that we may associate Device Information with your account. In addition, we may associate a Device with your account. We may combine this information with other information that we have collected about you.
(d) Collection and use of public information
We may also collect, use, store, transfer, share, and disclose your personal data that is publicly available for the purposes setout in this privacy policy.
Children
The Site is intended for use by adults only. ABS does not sell products intended for purchase by children and does not therefore knowingly or intentionally collect personal data from children. Youth-oriented products are sold for purchase by adults only. Please only use this Site if you are aged 18 or over.
4.1 We may use your personal data for a variety of business purposes, which we have set out below.
(a) To conduct our business and provide you with our services and access to our Site
To conduct our business, including to enable you to use our services and Site, to respond to your queries, to carry out our obligations arising from any agreements entered into between you and us and to contact you in connection with the foregoing.
(b) To communicate with you (about updates and changes)and provide you with customer support
To communicate with you about updates to our terms, services and Site and to provide you with customer support and to respond to your requests, comments, questions, or concerns, and to contact you if we have trouble processing your order. Such communications are provided by various means, including emails. Calls may be recorded for training and monitoring purposes.
(c) In relation to fraud prevention
To prevent fraud as may be required by applicable law and regulation and best practice at any given time. If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them.
(d) To allow you to use interactive features of the Site
To allow you to post testimonials, reviews or comments. Please note that such testimonial, review or comment may be read, collected and used by anyone.
(e) To ensure our Site content is relevant and to maintain the security of our Site
To ensure that content from our Sites is presented in the most effective and secure manner for you and for your device.
(f) For research and development purposes
To analyze your personal data in order to better understand your and our other clients’ services and marketing requirements, to better understand our business and develop our products, services and Site. In order to do this, we may apply profiles to you based on your personal data and behavioural information (such as the pages on the Site you have visited or interacted with, including by reference to personal data legitimately obtained and shared with us by third parties or publicly available data). Such profiles may be used as part of our advertising, analytics, security and provision of support.
(g) Website analytics
To understand and analyze your online experiences and to determine what events, products and services are likely to be of interest to you, we may combine your visitor session information or other information collected through tracking technologies (whether you are logged in or not) with personal data.
(h) To enforce our terms and in connection with legal or regulatory obligations
We may process your personal data to enforce our terms and to comply with our legal and regulatory requirements or dialogue with regulators/judicial proceedings/court orders as applicable which may include disclosing your personal data to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so.
(i) To reorganize or make changes to our business
In the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party;(ii) are sold to a third party; or (iii) undergo a re-organization, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale or re-organization. We may also need to transfer your personal data to that re-organized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this policy.
We use cookies and similar technologies (including device identifiers) in relation to the Site.
5.1 What are cookies?
A cookie is a small text file that is generated by a website, including the Site, and is stored on your device. When you access the Site, a number of cookies used by ABS and third parties are sent to your browser and stored on your device. When you next visit the Site, ABS and the third parties will use this information to recognize and remember your device. Third parties may also use this to recognize you when you are on other websites and mobile applications. Cookies are useful for a variety of purposes. For example, they allow you to navigate between pages efficiently and allow us to remember preferences and generally improve your user experience. They are also used to tailor advertising to your interests through tracking your browsing across websites. Session cookies are deleted when you close your browser. Persistent cookies remain on your device after you close your browser. Cookies set by ABS are first-party cookies. Cookies set by third parties are third-party cookies. Please note that ABS has no access to, or control over, third-party technologies and information about their data collection practices should be found on their respective websites.
5.2 What cookies does ABS use?
We describe below the categories of cookies that are set by ABS and its partners when you visit the Site.
(a) Strictly necessary cookies
These cookies are essential in order to enable you to move around the Site and use its features and cannot be turned off. Without these cookies, services you have asked for cannot be provided. Therefore, you cannot disable these cookies.
(b) Performance cookies
We make use of performance cookies to analyze how our visitors use the Site and to monitor the Site’s performance. This allows us to provide a high quality experience by customizing our offering, and quickly identifying and fixing any issues that arise.
For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. The information collected by these cookies is not associated with your personal data by us or by our contractors.
(c) Functional cookies
These cookies are used to provide you with certain functionality on the Site. For example, to improve the performance of our services and the Site, to maintain security on the Site and to prevent and detect fraud, and to display certain web page content based upon your browser type and other device information.
(d) Advertising cookies
ABS and various third party ad partners may use cookies and other tracking technologies to collect information about the browsing habits associated with your device to further personalize your experience such as through the use of targeted advertisements and special offers that are more relevant to you and your interests. We may allow some third parties, including Facebook, to set cookies both when you visit our Site and when you use certain features on our Site (such as clicking “Like”, “Share” and “tweet” buttons). These third parties link the information that they collect through the use of these cookies with the information that they hold about you through your use of their service in order to present you with targeted advertising via their platforms. In other situations, third parties use cookies so that they can retarget Rosewill’s products to you when you visit other websites or mobile applications, or to predict what advertisements about third party products are likely to be of interest to you based on your browsing activities.
5.3 Other tracking technologies
In conjunction with cookies, we may utilize other tracking technologies to understand how you access and use our Site and services. These tracking technologies may include:
(a) Log files and IP address
We use device information and IP addresses (and ask for confirmation if this is correct) to analyze trends, administer the Site, track user movement, and gather broad demographic information for aggregate use. An IP address is a numeric code that identifies your computer on the internet. We may store the information in log files (i.e. files which record events), or other types of files, which may be combined with other information that we have collected about you.
(b) Web Beacons and pixels
The Site and our emails and advertisements may contain web beacons. A web beacon is a small graphic image, such as a pixel or GIF, which is placed on a web page, email, or advertisement and is used to provide information on when and how you access and use the Site, and services and emails. We may use this information for various purposes, including to develop statistical information and to determine features that most interest you for the purpose of providing more personalized content. With respect to emails, we may use this information to determine which of our emails are more interesting to you and whether you wish to continue receiving such emails if you do not open them. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you should select to receive emails from us in plaintext rather than HTML, and you should not click links that we send you.
5.4 “Do Not Track Signals”
Some web browsers have a “Do Not Track” feature that, when turned on, signals to websites the user visits that the user does not want to be tracked. At this time, the Site does not respond to “Do Not Track” signals or similar mechanisms. If you would like additional information about online tracking and various opt-out mechanisms, please see https://youradchoices.com
5.5 Managing and disable cookies on the Site
Our website
You can manage cookies through your browser’s settings (http://allaboutcookies.org provides explanations as to how to do this). Please note that some of the uses of the Site and the services provided on the Site may not function if cookies are disabled. Please note that not all tracking will stop even if you delete cookies.
We may share or disclose your personal data for the purposes set out in section 4above to third parties. These third parties include:
(a) Service providers
Such service providers may include:
· Third-party companies to perform functions on our behalf e.g. data analysis; and
· IT cloud and hosting providers.
(b) Advisors
Such advisors may include legal, financial, business or other advisors.
(c) Other users of the Site
As mentioned above, any personal data you make available publicly such as by your reviews, comments or testimonials will be shared with other users of the Site.
(d) Affiliated companies
We may share your personal data we collect with all ABS parent companies, subsidiaries, and affiliates.
As our business continues to evolve, we may acquire, establish or sell business units or subsidiaries. Customer data is one of the business assets that would be transferred in these types of transactions. In such a situation, your personal data would only be used in a manner consistent with this privacy policy.
(e) Third parties as required by law or regulation
We may disclose your personal data as required bylaw or regulation, and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on ABS.
We may collect, use, store, transfer, share, and disclose non-personal information for any purpose (subject to applicable law).
Security
8.1 No data transmission over the Internet or websites can be guaranteed to be secure from intrusion. However, ABS takes commercially reasonable efforts to protect its customers’ personal data.
8.2 If you have any questions or concerns about ABS’s security practices, you can send us an email at customercare@abs.com.
General overseas transfers
9.1 Our servers and offices are located in the United States, and as a result, we may collect, process, store, share, and transfer your personal data in the United States.
9.2 As such, you understand and acknowledge that your personal data may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the country in which you are located, including to our servers and offices in the United States.
9.3 These countries may not provide the same level of data protection as your home country; however, we will take steps to ensure that your personal data that is transferred outside your home country is safeguarded inline with this privacy policy.
10.1 Our retention periods for personal data are based on business needs and legal requirements.
10.2 We will retain your personal data while we are using it, for purposes described in the section 4 above. We may continue to retain it after we have ceased such uses for certain legitimate business purposes. We may also continue to retain your personal data to meet our legal requirements or to defend or exercise our legal rights.
10.3 The length of time for which we will retain your personal data will depend on the purposes for which we need to retain it. After we no longer need to retain your personal data, we will delete it or securely destroy it in accordance with our records retention policy.
11.1 ABS operates in states with data protection laws which provide different rights to individuals in respect of access, deletion, rectification and limiting processing of personal information. When you submit a request to exercise your rights, we will need to check your entitlement prior to answering a request. Please note that your rights may be subject to certain exemptions as set out in applicable data protection law(s).
11.2 In general, the right to require us to update any inaccuracies in the personal data we hold is likely available to you regardless of where you are located.
11.3 In some states you have certain rights pertaining to your personal data, including: the right to delete, the right to opt out, the right to access your Personal data, and the right not be discriminated against. To exercise your rights under any applicable law, excluding the California Consumer Privacy Act (the “CCPA”), please submit a verifiable request to us by emailing customercare@abs.com or by contacting us as per section 1 of the privacy policy above. If you are a resident of California, please see Appendix 1 for additional information concerning your rights under the CCPA.
11.4 Contacting us
If you have any queries or complaints about our use of your information, please contact us directly at customercare@abs.com.
Cookie Settings
12.1 You can manage cookies through your browser’s settings.
13.1 We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If these changes are material, we will take steps to inform you of these.
13.2 We will update the date of this document each time it is changed.
The privacy policy contained herein became officially effective September 27th 2020
Where California privacy laws apply (if you are a consumer resident in California) the following additional provisions apply:
i. The provisions of this section I apply in addition to section 3, section 4 and section 6 of the privacy policy.
ii. The information that we collect is set out in the main body of the Privacy Policy. We further detail it below in accordance with California privacy requirements:
Identifiers such as areal name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
To perform services on behalf of ourselves, including providing you customer service and for the purposes set out in section 4 of the privacy policy.
Personal information is sold or disclosed in accordance with section 6 of the privacy policy. Recipients include service providers[1]; advisors; other Site users (where applicable); our affiliated companies; ; and other parties as required for legal and regulatory purposes.
Your signature, physical characteristics or description, telephone number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
To perform services on behalf of ourselves, including servicing your account and providing you customer service and for the purposes set out in section 4 of the privacy policy.
Personal characteristics, such as your gender, age, date of birth, citizenship status, and marital status.
Commercial information, including records products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
N/A
Biometric information
N/A
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet web site, application, or advertisement.
Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards and for the purposes set out in section 4 of the privacy policy.
Geolocation data
To perform services on behalf of ourselves, including providing you customer service and for the purposes set out in section 4 of the privacy policy
Audio, electronic, visual, thermal, olfactory, or similar information
N/A
Professional or employment-related information
N/A
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act.
N/A
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
To perform services on behalf of ourselves, including providing you customer service and for the purposes set out in section 4 of the privacy policy.
Any other such personal information as set out in section 4 of the privacy policy.
To perform services on behalf of ourselves, including providing you customer service and for the purposes set out in section 4 of the privacy policy.
iII. We may aggregate or de-identify any personal information that we collect in connection with our services, such that the information is no longer personally identifiable or attributable to you. We may use such aggregated information for our own legitimate business purposes without restriction.
iv. We do not sell the personal information of minors under 16 years of age without affirmative authorization.
i. The provisions of this section II apply in addition to section 11 and section 12 of the privacy policy.
ii. As a California resident, you have the right:
· to request access to the personal information we have about you;
· to request that we delete personal information about you;
· to opt-out of our use, transfer, exchange or disclosure (including to third parties) of personal information about you; and
· not to be discriminated against based upon whether you decide to opt-out.
iii. You have the right to request that we disclose to you what information we collect, use, disclose, and sell. Under California law, “sell,” “selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. You also have the right to request that a business delete any personal information about you which we have collected about you. We do not “sell” personal information under the California privacy laws. We do not sell the personal information of minors under 16 years of age without affirmative authorization.
iv. Please note for your protection, any request sent to us to access or delete your personal information will be subject to the following verification procedure: upon your submission of a request using one of the methods described in paragraph viii, below, we will send an email confirmation to the email address we have on file for you requiring you to confirm your request. When you have completed this two-step process ABS will verify the information that you provide in your request against information we have on file for you. We reserve the right to deny your request if we cannot verify your identity. Where we deny your request in whole or in part, we will endeavor to inform you of the denial, provide an explanation of our actions, and provide the reasons for the denial.
v. ABS does not sell personal information.
vi. We shall not discriminate against you for exercising any of your above rights.
vii. You may designate an authorized agent to make a request to exercise your rights on your behalf. To designate an authorized agent to make a request to exercise your rights under the CCPA on your behalf, then please complete and return the Agent Authorization Form. Your authorized agent must be able to provide to us written proof that you have authorized the agent to act on your behalf. For your protection, we reserve the right to deny any request from an agent who does not submit proof that they have been authorized to act on your behalf. We reserve the right to deny any request from an agent if we cannot verify your identity or the agent’s identity.
viii. To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by contacting us as per section 1 of the privacy policy above.
[1] Service providers are legal or natural persons who perform services for us or on our behalf, including for the purposes of operating our website and apps, assisting us to perform business functions and operations, and fulfilling requests by you. This could include, and is not limited to, web hosting providers, app hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, and professional advisors such as accountants, solicitors, business advisors and consultants