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�ټ��ֵ�����, Inc. (“�ټ��ֵ�����,” “we,” “us,”) is concerned about online privacy issues and wants you to be familiar with how we collect, use and disclose your Personally Identifiable Information (as defined below). This Privacy Policy (the “Policy”) describes our practices in connection with Personally Identifiable Information that we collect through our website located at / (the “Site”). This Policy does not address our practices regarding information that we collect through any website, or by any other means, other than through the Site; nor does this Policy govern the collection, use or disclosure of information by any of our affiliates (collectively, “Affiliated Entities”) or by third parties.

If you are a California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, or Virginia resident, please refer to the “Additional Information Regarding California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia” section at the end of this Policy for more information about our practices and how to exercise your rights, including with respect to personal information that we collect other than through the Site.

By using the Site, you agree to the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not use the Site. We reserve the right to change this Policy without prior notice. You can determine when this Policy was last revised by referring to the “LAST UPDATED” legend at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site. Use of the Site following such changes constitutes your acceptance of the revised Policy then in effect.

Note Regarding the Use of the Site by Children: The Site is not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide Personally Identifiable Information through the Site.

�ټ��ֵ����� gathers two basic types of information through the Site: “Personally Identifiable Information” (PII) and “Non-Personally Identifiable Information” (Non-PII). Personally Identifiable Information is information that identifies you as an individual, or relates to an identifiable person, including: name, postal address, telephone number, email address, and credit or debit card number. Non-Personally Identifiable Information is aggregated information, demographic information, IP addresses and any other information that does not reveal your specific identity or does not directly relate to an individual.

Personally Identifiable Information

You do not have to provide PII to use the Site. However in order for you to take advantage of particular opportunities provided through the Site (for example, to register for email, to submit a job application or ask a question), we may require that you furnish PII. We collect PII from you through the Site such as your name, postal address, telephone number or email address, only when you voluntarily provide it to us.

We use a third-party payment service (“Payment Service”) to collect payments made through the Site when purchasing a �ټ��ֵ����� gift card online. We also use a third-party service to collect online donations (“Donation Service”). If you wish to purchase a gift card or make a donation through the Site you will be directed to a web page that is hosted by the Payment Service (or the Payment Service’s service providers) or the Donation Service, and not by �ټ��ֵ����� (the “Payment Service Page” or the “Donation Service Page”). Any PII that you provide through the Payment Service Page or the Donation Service Page will be collected by the Payment Service or the Donation Service, and not by �ټ��ֵ�����, and will be subject to Payment Service’s or Donation Service’s privacy policy, rather than this Policy. �ټ��ֵ����� has no control over, and shall not be responsible for, Payment Service’s or Donation Service’s use of information collected through the Payment Service Page or the Donation Service Page. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE COLLECTION AND USE OF INFORMATION THROUGH THE PAYMENT SERVICE PAGE OR THE DONATION SERVICE PAGE, OR THE PRIVACY OR INFORMATION PRACTICES OF PAYMENT SERVICE OR DONATION SERVICE.

Non-Personally Identifiable Information

When you visit and interact with the Site, �ټ��ֵ����� and its third-party service providers may collect Non-PII (for example, a catalog of the Site pages you visit). Non-PII is generally collected through the Site from five different sources:

1. server log files,
2. environmental variables,
3. cookies,
4. pixel tags and other similar technologies, and
5. information that you voluntarily provide to

Server Log Files

Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We and our service providers use IP addresses for purposes such as calculating Site usage levels, helping diagnose problems with the Site’s servers and administering the Site. Collecting IP addresses is standard practice on the internet and is done automatically by many websites. We may also derive your approximate location from your IP address.

Environmental Variables

We and our service providers may also collect certain environmental variables such as your computer type (Windows or Macintosh), screen resolution, OS version, internet browser and internet browser version. These environmental variables are collected by most browsers, and can be used to optimize your experience on the Site.

Cookies

We and our service providers may use “cookies” in connection with the Site. Cookies are data that a web server transfers to an individual’s computer for record keeping and other purposes including to facilitate users’ ongoing access to and use of a particular website, as well as to understand how the site is used. Cookies are an industry standard used by most websites; cookies do not cause damage to your computer systems or files. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie or cookies from a particular website to your computer. We use Google Analytics, which uses cookies and other similar technologies to collect and analyze information about Site use and report on activities and trends. This service may also collect information regarding the use of other websites. You can learn about Google’s practices by going to and opt out of them by downloading the Google Analytics opt-out browser add-on, available at . At this time we do not respond to browser do-not- track signals.

Pixel Tags

We and our service providers may also use so-called “pixel tags,” “web beacons,” “clear GIFs” or similar means in connection with Site pages and HTML-formatted email messages to, among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile aggregate statistics about Site usage and response rates.

Interest-based Advertising

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use our Site and other websites, apps or online services, based on information relating to your access and use of our Site and other websites, apps and services on any of your devices, as well as information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit and . You may download the AppChoices app at to opt out in mobile apps.

Information That You Voluntarily Provide

�ټ��ֵ����� also collects Non-PII (e.g., your interests, your geographic location, etc.) when you voluntarily provide such information to us. Such information constitutes Non-PII because, unless combined with PII, it does not personally identify you or any other user. Additionally, we may aggregate PII in a manner such that the end product does not personally identify you or any other user of the Site, for example, by using PII to calculate the percentage of our users who have a particular telephone area code. Such aggregate information is considered Non-PII for purposes of this Policy.

Personally Identifiable Information

We may use PII about you in the following ways:

Fulfillment of Requests

�ټ��ֵ����� may use PII about you to fulfill the purpose for which such PII was provided (e.g., to send newsletters to you or respond to your inquiries).

Administrative Communications

From time to time, in our sole discretion, we may use PII about you to send to you important information regarding the Site, changes to our terms, conditions, and policies or other administrative information. Because this information may be important to your use of the Site, you may not opt out of receiving such communications.

Other Communications

From time to time, in our sole discretion, we may use PII about you to inform you of products, programs, services and promotions that we believe may be of interest to you, including using PII to personalize, advertise and market our products. If you would prefer that we do not send electronic marketing messages to you, please see the “Opt Out” section below.

Promotions

We may operate sweepstakes, contests and similar promotions (collectively, “Promotions”) through the Site. We typically ask you for certain PII when you enter and, if applicable, win a Promotion. You should carefully review the rules, if any, of each Promotion in which you participate through the Site, as they may contain additional important information about �ټ��ֵ�����’ use of PII about you. To the extent that the terms and conditions of such rules concerning the treatment of PII about you conflict with this Policy, the terms and conditions of such rules shall control.

Business Purposes

We may also use PII about you for our general business purposes, including to: provide our products and services; conduct research and analytics; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit and other internal functions, such as internal investigations; comply with law, legal process and internal policies; maintain records; and exercise and defend legal claims.

Non-Personally Identifiable Information

Because Non-PII does not personally identify you, we may use such information for any purpose, except where we are required to do otherwise under applicable law. In addition, we reserve the right to share such Non PII, which does not personally identify you, with Affiliated Entities and other third parties, for any purpose. If we are required to treat Non-PII as PII under applicable law, then we may use and disclose it for the purposes for which we use and disclose PII as detailed in this Privacy Policy.

In some instances, we may combine Non-PII with PII (such as combining your name with your geographic location). If we do combine any Non-PII with PII, the combined information will be treated by us as PII hereunder as long as it is so combined.

Third-Party Service Providers

We work with third parties that provide services including but not limited to data analysis, web hosting, managing our mailing lists, advertising, order fulfillment and other administrative purposes. We reserve the right to share PII about you with such third parties for the purpose of enabling these third parties to provide such services.

Promotions

We reserve the right to share the PII you provide in connection with Promotions with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us) or otherwise in accordance with the rules applicable to such Promotion. You should carefully review the rules, if any, of each Promotion in which you participate through the Site, as they may contain additional important information about a sponsor’s or other third party’s use of PII about you. To the extent that the terms and conditions of such rules concerning the treatment of PII about you conflict with this Policy, the terms and conditions of such rules shall control.

Trusted Third Parties

We may share your PII with trusted third parties, including our third-party business and marketing partners, such as financial services institutions, to provide you with opportunities to obtain additional products and services.

Assignment

We reserve the right to transfer any and all information that we collect from Site users to an Affiliated Entity or a third-party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of �ټ��ֵ�����’ business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).

Law enforcement; emergencies; compliance

We reserve the right to use and disclose PII about you to others:

1. as required or permitted under applicable law;
2. to comply with legal process;
3. to respond to governmental requests;
4. to enforce our Terms of Service;
5. to protect our operations or those of any Affiliated Entities;
6. to protect the rights, privacy, safety or property of �ټ��ֵ�����’ and dd’s DISCOUNTS, the Affiliated Entities, you or others; and to permit us to pursue available remedies or limit the damages that we may sustain

Third-party Sites

The Site may contain links to third-party websites. These linked sites are not under �ټ��ֵ�����’ control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by �ټ��ֵ����� or any Affiliated Entities. If you provide any PII through any such third-party website, your transaction will occur on such third party’s website (not the Site) and the PII you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, THE AFFILIATED ENTITIES.

 

Security

We seek to use reasonable organizational, technical and administrative measures to help protect against the loss, misuse and alteration of the PII under our control. Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. As a result, although we strive to protect PII about you, we cannot ensure the security of any information you transmit to us through or in connection with the Site or that is stored by us. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with the Section called “Contacting Us” below (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem). �ټ��ֵ����� will never ask for PII in an unsolicited phone call or email.

 

Opt Out

If you do not wish to receive marketing-related emails from us, you may opt out by following the instructions contained in each such email.

 

Jurisdictional Issues

The Site is controlled and operated by �ټ��ֵ����� from the United States and is not intended to subject �ټ��ֵ����� or any Affiliated Entity to the laws or jurisdiction of any state, country or territory other than that of the United States. Your PII may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Site, you consent to the transfer of information to countries outside your country of residence, including the United States, which may have data-protection rules that are different from those of your country.

 

Nevada Residents as Covered by Nevada Privacy Law

�ټ��ֵ����� does not sell Covered Information as defined under Nevada law. If you would like to make a further inquiry regarding the selling of your Covered Information, as defined under Nevada law, please contact us by emailing: privacy @ros.com and using the subject line “Nevada Privacy Request.”

 

Contacting Us

If you have any questions regarding this Policy, please contact us by using the form located on the Contact Us page.

 

Additional Information Regarding California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah and Virginia

This section applies to California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia residents and supplements the information provided above in the Privacy Policy. This section does not apply to our employees or contractors where the personal information we collect about those individuals relates to their current, former, or potential role with us. If you are a California employee please contact your HR representative for details on how we handle your employee personal information pursuant to California privacy law.

 

Collection, Processing, Disclosure, Sale and Sharing of Personal Information

The following section details which categories of personal information we collect and process both online and offline, as well as which categories of personal information we disclose to third parties for our operational business purposes, including within the preceding 12 months. The section also details the categories of personal information that we “sell” or “share” for purposes of cross-context behavioral or targeted advertising, including within the preceding 12 months.

�����Գپ�fie����, such as name, contact information and online identifiers:

Disclosed to Which Categories of Third Parties for Operational Business Purposes: Our affiliates; trusted third-party service providers; sponsors of sweepstakes, contests and similar promotions; trusted third-party business and marketing partners, such as financial services institutions; legal authorities

Sold to Which Categories of Third Parties: Ad networks

 Shared with Which Categories of Third Parties for Cross-Context Behavioral or Targeted Advertising: Ad networks

Processing Purposes: Fulfillment of Requests, Administrative Communications, Other Communications, Promotions and Business Purposes (see the section above entitled “How Does �ټ��ֵ����� Use Information Collected from Me?” for a detailed description of each processing purpose)

Personal information as defined in the California customer records law, such as signature and payment card number:

Disclosed to Which Categories of Third Parties for Operational Business Purposes: Our affiliates; trusted third-party service providers

  Sold to Which Categories of Third Parties: None

Shared with Which Categories of Third Parties for Cross-Context Behavioral or Targeted Advertising: None

Processing Purposes: Fulfillment of Requests, Administrative Communications, Other Communications, Promotions and Business Purposes (see the section above entitled “How Does �ټ��ֵ����� Use Information Collected from Me?” for a detailed description of each processing purpose)

Commercial Information, such as transaction information and purchase history

Disclosed to Which Categories of Third Parties for Operational Business Purposes: affiliates Our; trusted third-party service providers; sponsors of sweepstakes, contests and similar promotions; legal authorities

Sold to Which Categories of Third Parties: None

Shared with Which Categories of Third Parties for Cross-Context Behavioral or Targeted Advertising: None

Processing Purposes: Fulfillment of Requests, Administrative Communications, Other Communications, Promotions and Business Purposes (see the section above entitled “How Does �ټ��ֵ����� Use Information Collected from Me?” for a detailed description of each processing purpose)

Internet or network activity information, such as browsing history and interactions with our website

Disclosed to Which Categories of Third Parties for Operational Business Purposes: Our affiliates; trusted third-party service providers; sponsors of sweepstakes, contests and similar promotions; legal authorities

Sold to Which Categories of Third Parties: Ad networks

 Shared with Which Categories of Third Parties for Cross-Context Behavioral or Targeted Advertising: Ad networks

Processing Purposes: Fulfillment of Requests, Administrative Communications, Other Communications, Promotions and Business Purposes (see the section above entitled “How Does �ټ��ֵ����� Use Information Collected from Me?” for a detailed description of each processing purpose)

Audio/Video Data. Audio, electronic, visual, and similar information, such as audio and video recordings

Disclosed to Which Categories of Third Parties for Operational Business Purposes: Our affiliates; trusted third-party service providers

  Sold to Which Categories of Third Parties: None

Shared with Which Categories of Third Parties for Cross-Context Behavioral or Targeted Advertising: None

Processing Purposes: Fulfillment of Requests, Administrative Communications and Business Purposes (see the section above entitled “How Does �ټ��ֵ����� Use Information Collected from Me?” for a detailed description of each processing purpose)

Inferences drawn from any of the personal information listed above to create a profile about, for example, an individual’s preferences or characteristics

Disclosed to Which Categories of Third Parties for Operational Business Purposes: Our affiliates; trusted third-party service providers

Sold to Which Categories of Third Parties: None

Shared with Which Categories of Third Parties for Cross-Context Behavioral or Targeted Advertising: None

Processing Purposes: Business Purposes (see the section above entitled “How Does �ټ��ֵ����� Use Information Collected from Me?” for a detailed description of each processing purpose)

Sensitive Personal Information

Personal information that reveals an individual’s social security, driver’s license, state identification card, or passport number; 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; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status, or union membership; the contents of mail, email, and text messages unless �ټ��ֵ����� is the intended recipient of the communication

Disclosed to Which Categories of Third Parties for Operational Business Purposes: Our affiliates; trusted third-party service providers

  Sold to Which Categories of Third Parties: None

Shared with Which Categories of Third Parties for Cross-Context Behavioral or Targeted Advertising: None

Processing Purposes: Fulfillment of Requests and Business Purposes (see the section above entitled “How Does �ټ��ֵ����� Use Information Collected from Me?” [hyperlink to section if possible] for a detailed description of each processing purpose)

We may also disclose your personal information to a third party in the event of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We do not knowingly sell or “share” (for purposes of cross-context behavioral advertising) the personal information, including the sensitive personal information, of minors under age 16.

Purposes for the Collection, Use and Disclosure of Sensitive Personal Information

Subject to your consent where required under applicable law, we collect, use and disclose sensitive personal information for purposes of: providing goods or services as requested; ensuring safety, security, and integrity; countering wrongful or unlawful actions; short term transient use such as displaying first party, non-personalized advertising; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, storage, or similar services on behalf of our business; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about a consumer. We do not use sensitive personal information beyond these purposes.

 

Retention Period

We retain each category of personal information, including sensitive personal information, for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide services to you, for example, for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;

Whether there is a legal obligation to which we are subject, for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them; or

Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations.

Sources of Personal Information

We collect personal information from you, such as when you interact with our Site or other online services, make a purchase in our stores, contact customer service, or participate in a contest. We also collect personal information from other categories of sources, such as publicly available databases and joint marketing partners, when they share the information with us.

Individual Rights and Requests

If you are a California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, or Virginia resident, you may, subject to applicable law, make the following requests.

1.  Request to Know

You may request to know whether we process your personal information and to access such personal information, including a copy of the specific pieces of your personal information in a portable format.

If you are a California resident, you may also request that we disclose to you:

The categories of personal information we collected about you and the categories of sources from which we collected such personal information;

The business or commercial purpose for collecting, selling or “sharing” personal information about you;

The categories of personal information about you that we sold or “shared” and the categories of third parties to whom we sold or “shared” such personal information; and

The categories of personal information about you that we otherwise disclosed or disclosed, and the categories of third parties to whom we disclosed such personal information.

If you are a Delaware resident, you may also request that we disclose to you the categories of third parties to whom we disclosed your Personal Information.

If you are an Oregon resident, you may also request that we disclose to you:

The categories of personal information we process about you; and   The third parties to whom we have disclosed personal information.

 

2.  Request to Correct

You may request that we correct inaccuracies in your personal information.

 

3.  Request to Delete

You may request that we delete your personal information.

 

To make a Request to Know, Correct or Delete, please contact us at 1-800-603-3519 or We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you, such as identifying documents, in order to verify your identity and protect against fraudulent requests. If you make a Request to Delete, we may ask you to confirm your request before we delete your personal information.

 

4.  Request to Opt Out of Sale

You may request to opt out of any future “sale” of your personal information by clicking on the “Do Not Sell or Share My Personal Information/Your Opt-Out Rights” link on the footer of this page or by contacting us at 1-800-603-3519.

 

5.  Request to Opt Out of “Sharing” / “Targeted Advertising”

You may request to opt out of any future “sharing” of your personal information for purposes of cross-context behavioral advertising or any future processing of your personal information for purposes of targeted advertising by clicking on the “Do Not Sell or Share My Personal

Information/Your Opt-Out Rights” link on the footer of this page or by contacting us at 1-800- 603-3519.

We also process opt-out preference signals, such as the Global Privacy Control. These signals set your opt-out preferences only for the particular browser or device you are using. For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/.

Right to Non-Discrimination

You have the right to be free from unlawful discrimination for exercising your rights under applicable privacy law.

Appeal Process

If you are a Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, or Virginia resident and we refuse to take action on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us at .

Authorized Agents

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “Individual Rights and Requests.” We will process the agent’s request consistent with applicable law. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent In addition, we may require that you verify your identity as described in the section entitled “Individual Rights and Requests” or confirm that you provided the agent permission to submit the request.

De-Identified Information

Where we maintain or use de-identified information, we will continue to maintain and use the de- identified information only in a de-identified fashion and will not attempt to re-identify the information.

California’s “Shine the Light”

If you are a California resident and prefer that we discontinue sharing your personal information on a going-forward basis with third parties for their direct marketing purposes, you may opt out of this sharing by emailing: privacy @ros.com