We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a "controller" of that personal information for the purposes of the GDPR. We are responsible for your personal information as a "business" under the CCPA/CPRA.
Key Terms.
It would be helpful to start by explaining some key terms used in this policy:
We, us, our
Racklify, Inc.
Our Data Protection Officer
Support@racklify.com
Personal information
Any information relating to an identified or identifiable individual
Personal Information We Collect About You.
We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
Name, email address, phone number, account name, IP address, and an ID or number assigned to your account
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Billing and shipping address, and credit and debit card information
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
Email address, account log-in, and account password
Characteristics of protected classifications under California or federal law.
Age or gender
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Purchases and engagement with the Site and/or Services
Biometric information
None
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
Interactions with our Site and/or Services
Geolocation data
Location enabled services such as WiFi and GPS
Audio, electronic, visual, thermal, olfactory, or similar information
None
Professional or employment-related information
Information you provide when you apply for a job with us
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)
Information you provide when you apply for a job with us
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Your interests, preferences and favorites
Racial or ethnic origin, religious or philosophical beliefs, union memberships, or citizenship or immigration status
None
Contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication
Your mail and email communications with us
Genetic Data
None
Processing of biometric information for the purpose of uniquely identifying a consumer
None
Health information
None
Sex life or sexual orientation
None
This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.
How Your Personal Information is Collected
We collect personal information from the following categories of sources:
You, directly in person, by telephone, text, or email and via our website
From a third party with your consent (e.g., your bank, stripe, Sumsub)
Advertising networks
Internet service providers
Data analytics providers
Government entities
Operating systems and platforms
Social networks
Data brokers
Publicly accessible sources (e.g., property records)
Cookies on our website
Our IT and security systems, including:
Door entry systems and reception logs
Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems
How and Why We Use Your Personal Information.
Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:
To comply with our legal and regulatory obligations
For the performance of our contract with you or to take steps at your request before entering into a contract
For our legitimate interests or those of a third party, or
Where you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for Our reasons To provide our Services to you
For the performance of Our Website and the Services provided therewith
To prevent and detect fraud against you
For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity
For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
Screening for financial and other sanctions or embargoes
For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you To comply with our legal and regulatory obligations
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information
For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records
For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products and/or services
Statutory returns
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments
For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to: * existing and former customers * third parties who have previously expressed an interest in our services * third parties with whom we have had no previous dealings
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
Credit reference checks via external credit reference agencies
For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts
For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations
The above table does not apply to special category personal information, which we will only process with your explicit consent.
EEA Data Subjects: Promotional Communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving promotional communications at any time by:
Contacting us at support@racklify.com
Using the “unsubscribe” link in emails or “STOP” number in texts
Updating your marketing preferences on our website
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who We Share Your Personal Information With
We routinely share personal information with:
Our affiliates
Service providers we use to help deliver our products and/or services to you, such as payment service providers, KYC, warehouses and delivery companies
Other third parties we use to help us run our business, such as marketing agencies or website hosts
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
Credit reporting agencies
Our insurers and brokers
Our bank[s]
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Personal Information We Sold or Disclosed for a Business Purpose.
In the preceding 12 months, we have sold or shared the following categories of personal information:
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
Characteristics of protected classifications under California or federal law
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
Geolocation data
Professional or employment-related information
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Categories of Personal Information We Disclosed for a Business Purpose.
In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers)
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
Characteristics of protected classifications under California or federal law
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Biometric information
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement)
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Sensitive personal information
9EEA Data Subjects: Where Your Personal Information is Held.
Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.
How Long Your Personal Information Will Be Kept
We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:
To respond to any questions, complaints or claims made by you or on your behalf
To show that we treated you fairly
To keep records required by law
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
EEA Data Subjects: Transferring Your Personal Information Out of the EEA.
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
With our offices outside the EEA
With your and our service providers located outside the EEA
If you are based outside the EEA
These transfers are subject to special rules under European and UK data protection law.
Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.
If you would like further information, please contact us (see “How To Contact Us” below).
EEA Data Subjects: Your Rights Under the GDPR.
Right to Be Informed
The right to know or be notified about the collection and use of your personal information
Right to Access
The right to be provided with a copy of your personal information (the right of access)
Right to Rectification
The right to require us to correct any mistakes in your personal information
Right to be Forgotten
The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing
The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object
At any time to your personal information being processed for direct marketing (including profiling)
In certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests
Right Not to be Subject to Automated Individual Decision-Making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.
Your Rights Under the CCPA.
You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You
You have the right to know:
The categories of personal information we have collected about you, including sensitive personal information
The categories of sources from which the personal information is collected
Our business or commercial purpose for collecting or selling personal information
The categories of third parties with whom we share personal information, if any, and
The specific pieces of personal information we have collected about you
Please note that we are not required to:
Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained
Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information, or
Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose
In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold, and
The categories of personal information that we disclosed about you for a business purpose.
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information.
To opt-out of the disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link in the footer of the Site.
Right to Limit Use of Sensitive Personal Information
You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
Perform the services or provide the goods reasonably expected by an average consumer who request those goods or services
To perform the following services:
(1) helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes,
(2) short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business,
(3) performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying consumer information, processing payments, providing financing, providing analytical services, providing storage, or providing similar services on behalf of the business, and
As authorized by further regulations
You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes
To limit the use of your sensitive personal information, visit our homepage and click on the “Limit the Use of My Sensitive Personal Information” link.
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Delete your personal information from our records, and
Direct any service providers to delete your personal information from their records
Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort
Please note that we may not delete your personal information if it is necessary to:
Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity
Debug to identify and repair errors that impair existing intended functionality
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law
Comply with the California Electronic Communications Privacy Act
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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
Comply with an existing legal obligation, or
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information
Right to Correction
If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:
Deny goods or services to you
Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
Provide a different level or quality of goods or services to you
Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems, which means we follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to Exercise Your Rights
If you would like to exercise any of your rights as described in this Privacy Policy, please:
Complete a data subject request form available on our website, or
Email us at support@racklify.com
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact directly you will need to provide us with:
Enough information to identify you (e.g., your full name, address and customer or matter reference number)
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill), and
A description of what right you want to exercise and the information to which your request relates
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
EEA Data Subjects. How to File a GDPR Complaint
We hope that we or our Representative can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
Changes to This Privacy Notice
This privacy notice was published on 6/10/24 and last updated on 6/10/24.
We may change this privacy notice from time to time–when we do, we will inform you via our website or other means of contact such as email.
How to Contact Us
Please contact us or our EU Representative by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
Our contact details Our EU Representative’s contact details 933 Montgomery Ave., #1085, Narberth, PA. 19072
Same
support@racklify.com
Same
Do You Need Extra Help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).