Last modified:  March 12, 2020

Introduction

Rokform LLC (“Company” or “we”) respects your privacy and is committed to protecting it through our compliance with this privacy policy (this “Policy”).  This Policy describes how we collect, use and share Personal Information in connection with promoting and selling our products and operating the Company’s website,www.rokform.com (the “Website”).  It also explains related rights and choices you may have.  Personal Information is defined below in the Section called “What is ‘Personal Information’?”

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.   You may see other privacy notices when we collect your Personal Information for certain purposes.  Those notices supplement this Policy.  This Policy also contains a statement specific to California residents and another statement specific to individuals in the European Economic Area (“EEA”) based on laws in those areas.  Those statements supplement the rest of this Policy, but to the extent they differ from other parts of the Policy, the statements govern in their respective areas.

To the extent our Website contains links to third party websites, please note that we do not own, operate, or control those sites, and this Policy does not cover those sites, which may have their own privacy policies that you should review.

By Using the Website in any manner, you agree to this Policy and you consent to the collection, transfer, processing, storage, disclosure and other uses of your Personal Information as described in this Policy, unless further consent is required under applicable law.  

This Policy may change from time to time.  For information about our policies regarding changes to the Policy, see the Section below called “Changes to Our Privacy Policy”.  Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

What is “Personal Information”?

 

When we say “Personal Information,” we mean “personal information” or “personal data” as defined in laws that may apply to you.  Generally speaking, this includes your unique identifiers (full name, phone number, email address, account number, etc.), and information about your characteristics, conditions or behavior that is associated with one of your identifiers or could otherwise reasonably be linked to you. 

“Non-Personal Information,” on the other hand, has been anonymized, aggregated or de-identified such that it cannot reasonably be linked to a particular individual.

 

 

Personal Information We Collect and How We Collect It

 

We collect several categories of Personal Information, as listed below.  We collect this information:

  • Directly from you when you provide it to us, whether in person, online or over the phone;
  • Automatically from your device or browser as you navigate through or use the Website;or
  • From our vendors and other third party sources.

 

Information You Provide to Us. 

 

We may collect the following categories of Personal Information from you directly when you visit our Website; register an account with us; shop or make a purchase on the Website; fill out a form on the Website; subscribe to one of our newsletters; call to make an inquiry or purchase; interact with one of our representatives at a trade show or other event; or otherwise communicate with us:

  • “Identifiers”, such as first and last name, telephone number, address, email addressor similar information
  • “Financial Information”, such as payment card information
  • “Demographic Information”, such as age and date of birth
  • “Account Information”, such as account profile, purchase history, and billing information
  • “Transaction Information”, such as details of your transactions with us and the fulfillment of your orders
  • “User Content”, such as your ratings or reviews, or content in your comments, posts, communications or responses

 

Information We Collect Through Automatic Data Collection Technologies. 

 

As you navigate through and interact with our Website or emails we send, we may use automatic data collection technologies to collect certain types of data from your device or browser.  Where feasible, this collection may be limited to Non-Personal Information, but collection may include the following categories of Personal Information:

 

  • Identifiers, such as IP address, device ID, cookies or cookie ID, and similar information
  • “Device/Browser Information”, such as the name of your internet service provider (ISP), operating system, device type, browser type and configuration, and information about whether the device has downloaded and installed our software
  • “Usage Information and Browsing History”, such as Website interactions (including traffic data, access times, accessed pages, logs, and other communication data and the resources that you access and use on the Website), email interactions (details of whether or not our users have opened our emails),, browsing history (including the pages from which you were referred to our Website)
  • “Geolocation Data”, such as the approximate location of your device when you interact with our Website

 

The technologies we use for this automatic data collection may include browser cookies and other online tracking technologies (collectively, “Cookies”).  To learn more about how we and our partners use Cookies, please see our Cookie Notice

 

How And Why We Use Personal Information

 

We use Personal Information for the following purposes:

  • To present our Website and its contents to you;
  • To personalize and improve your experience with the Website;
  • To provide you with information, products, or services that you request from us;
  • To fulfill any other purpose for which you provide it;
  • To provide you with notices about your account and subscriptions, including expiration and renewal notices;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • To notify you about changes to our Website and any products or services we offer or provide though them;
  • To allow you to participate in interactive features on our Website;
  • To allow you to purchase products and process payments through the Website;
  • To provide you with periodic product newsletters and offers;
  • To contact you and provide you with help if you have a customer service issue;
  • To identify and protect you and maintain your account;
  • To notify you of new products or services we think you might be interested in;
  • In any other way we may describe when you provide the information; and
  • For any other purpose with your consent.

 

We may use Non-Personal Information for any purpose.

 

Disclosure and Sharing of Your Information

 

All Personal Information remains private with us and is not shared with outside organizations without your direction or consent except as described in this Policy.  We may disclose Non-Personal Information without restriction.

 

We may disclose or share information, including Personal Information, as follows:

 

  • Vendors. We may share Personal Information with contractors, service providers, and other vendors who provide services to us.  Examples of these services include hosting our website, sending marketing communications, or operating referral and rewards programs on our behalf.  Where necessary and appropriate, our vendors are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.  Our vendors include, but may not be limited to:

 

  • Analytics and Advertising Partners. We may share your Personal Information with analytics providers, advertising networks, or social media companies (at least some of whom are considered vendors) to measure performance of our Website or marketing efforts or to deliver personalized advertising about our products and services.  This sharing may involve the use of “Cookies,” some of which are placed by our partners, as explained in our Cookie Notice.  For example, when you visit our Website, our partner’s Cookie may cause your browser to automatically send a request to our partner’s server and provide our partner with your IP address, other Identifiers, and Usage Information & Browsing History.  Where necessary and appropriate, our agreements with these partners prohibit them from retaining, using or disclosing the Personal Information we share with them for any purpose other than providing us with analytics or advertising services.

 

As of the date of our last update to this Privacy Policy, our Vendors, Analytics Providers and Advertising Providers included:

 

Please note that the links to these third parties’ privacy policies and the information contained within them may change from time to time, and the links provided above may not be the most current.  If the links provided do not allow you to access those third parties’  privacy policies, please notify us by contacting us at privacy@rokform.com.

 

  • Change in Control or Merger.  We may disclose Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of the Company, whether as a going concern or as part of bankruptcy, assignment for the benefit of creditors, liquidation, or similar proceeding, or the application of laws or equitable principles affecting creditors’ rights generally, in which information, including Personal Information, held by the Company about our users is among the assets transferred.

 

  • To fulfill the purpose for which you provide it.

 

  • For any other purpose disclosed by us when you provide the information.

 

  • With your consent.

 

We may also disclose your information, including Personal Information:

 

  • To cooperate with government and law enforcement officials and private parties to enforce and comply with the law, including to comply with any court order, law, or legal process (including responses to subpoenas), including to respond to any government or regulatory request.
  • To enforce or apply any terms of use we may have and other agreements, including for billing and collection purposes.
  • To prevent or to stop activity that we believe is illegal or unethical.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and resolving disputes.

 

How We Store Your Information

 

All Personal Information is stored on restricted database servers.  We use industry standard measures to prevent the loss, misuse and alteration of your information once it is in our care.  Our hosting provider has access to the servers.  Our third party hosting provider has access to the servers on which your data is stored.  We use secure sockets layer technology for transmitting your data and encrypting passwords.

 

Choices You Have Over How We Use Your Personal Information

 

We strive to provide you with choices regarding the Personal Information you provide to us.  We are not, however, responsible for ensuring the confidentiality of your information, including Personal Information, if you choose to provide such information on our Website and opt to make such information accessible to all or some of the public.  Any Personal Information you choose to provide should reflect how much you want others to know about you as the information that you provide to the Website may be broadly and quickly disseminated.  You can control who has access to any files that you upload, but you understand that any shared files may be re-shared or copied.  Although we allow you to limit access to your files, please be aware that no security measures are perfect or impenetrable, and files that you share on the Website may become publicly available.  We cannot control the actions of other users with whom you share your files, nor can we guarantee that only authorized persons will view your files.

 

We have created mechanisms to provide you with the following control over your Personal Information:

  • Changing the Information Provided to Us. You may review, update, correct or delete Personal Information through your account.
  • Tracking Technologies, Analytics and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being set. If you disable or refuse cookies, please note that some parts of our Website may then be inaccessible or not function properly.
  • Promotional Offers from the Company. We may provide certain promotional offers to you by email newsletter if you sign up for such newsletters on our Website.  For instance, we may inform you about new products that might interest you in the body of the email newsletter.  You may elect to stop receiving our email newsletters.  If you do not wish to have your email address used by the Company to promote our products or services, you can opt-out by (1) checking the relevant box located on the form on which we collect your data (the registration form); (2) logging into the Website at any time and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes; or (3) sending us an email stating your request to privacy@rokform.com .  If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

 

Accessing and Correcting Your Information

 

You have rights to your data, and you can request to delete or transfer your data upon cancelling any subscriptions that you may have with us in accordance with this Policy.  You can review and change your some of your Personal Information by emailing privacy@rokform.com.

You can opt out of promotional emails at any time by emailing privacy@rokform.com, but you will still receive communications such as receipts, confirmation emails and customer service updates that are considered necessary to service your purchase orders.

 

We may not be able to delete your Personal Information except by also deleting your user account and information about any orders that you may have placed with us.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

 

Withdrawing Consent

 

You may also send us an email at privacy@rokform.com to withdraw any consent that you have provided us. We may not accommodate a request, for instance for deletion of Personal Information, if we believe the change would violate any law or legal requirement or cause the information to be incorrect, if we cannot authenticate the request, or if we believe the request is fraudulent.

 

Data Retention

 

We will retain your Personal Information as long as your account with us is considered to be active.  Unless you request to delete your Personal Information, we will retain your information for as long as your account is active, as needed to provide you and to communicate with you about our products.  If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us at 855-765-3676.  Deactivation of your account does not mean your Personal Information has been deleted from our database entirely.  To request removal of your data, please send an email to privacy@rokform.com.  While your account is active and even after it has been closed or you have requested deletion of your Personal Information, we will retain your Personal Information as long as we deem it reasonably necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Data Portability

 

To request a copy of the Personal Information that we retain about you, please send an email to privacy@rokform.com or write us at: Rokform LLC, Attn: Privacy, 16180 Scientific, Irvine, CA 92618.

 

Links to Third Party Sites

 

Our Website may contain links to third-party websites, products or services.  If you use these links, you will leave our site. Such links do not constitute or imply an endorsement, sponsorship or recommendation by us of the third party, the third-party website or the information contained therein, and we shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

 

Children Under the Age of 18

 

Our Website is not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18.  No one under age 18 may provide any information to the Website or through use of the Website.   If you are under 18, do not use this Website or provide any information on or through it, including through on or through any of the features on the Website.  No one under the age of 18 years old may register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.  If we learn that we have collected or received Personal Information (as defined in the Section from a child under 18 without verification of parental consent, we will delete that information.  If you believe that we might have any information from or about a child under 18 years of age, please contact us at 855-765-3676.

 

More Disclosures For California Residents

 

 

California Civil Code Section § 1798.83 permits California residents to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes.  Rokform does not disclose Personal Information to third parties for their direct marketing purposes.

 

California imposes certain legal requirements regarding “Do Not Track” disclosures.  The internet browsers that you use to visit our Website may provide certain “Do Not Track” capabilities.  Generally, browsers that have these features send a signal to web sites that inform the site operator that you do not wish for the site to track you.  We do not respond to these signals because there is not yet a common understanding of how to process these signals or a consensus on what “tracking” means.

 

This rest of this section makes additional disclosures to California residents (i.e., consumers), and describes rights they have, under the California Consumer Privacy Act of 2018, as amended, (the “CCPA”). 

 

California’s Attorney General has published proposed implementing regulations for the CCPA, but the regulations have not yet taken effect and remain subject to change.  The final regulations may alter how businesses have to comply with the CCPA.  Development of our CCPA compliance program is ongoing, and we may update this Policy again this year as a result.

 

You can learn more about the CCPA here:  https://oag.ca.gov/privacy/ccpa

 

Collection Of Personal Information

 

The following table describes which categories of Personal Information we collected about consumers within the past 12 months, consistent with how categories are organized in the CCPA.  For each category, we collected one or more of the examples listed. 

 

 

Category

Examples

Identifiers

Real name, signature, alias, address, telephone number, email address, Internet Protocol address, device identifier, browser cookies, web beacon, pixel tag, mobile ad identifier, other unique personal identifier, online identifier, account name, physical characteristics or description, or other similar identifiers.

 

Financial Information

payment card information (although we do not collect whole card numbers, only the last four digits)

 

 

Protected Classification Information

age (40 years or older), , marital status, sex (including gender, gender identity, gender expression,),  or veteran or military status.

Commercial Information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

 

Internet Activity.

 

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

 

Geolocation Data

 

Physical location or movements.

Sensory Data.

Audio, electronic or visual  information.

 

Professional or Employment-Related Information

 

Current or past job history.

Education Information

Level of education.

Inferences Drawn From Other Personal Information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

 

Sale Or Disclosure Of Personal Information

 

We do not sell Personal Information.  

 

Within the past 12 months, we disclosed the following categories of Personal Information for a business purpose :

  • Identifiers
  • Financial Information
  • Commercial Information
  • Internet Activity
  • Geolocation Data

 

Your Rights

 

California residents have the right to make the following requests to covered businesses.  The requests may be made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a person authorized by the consumer to act on the consumer’s behalf.

Right To Know About Collection, Disclosure or Sale of Personal Information                     

You have the right to request that a business disclose to you: (i) the categories and specific pieces of personal information the business has collected about you within the past 12 months, (ii) the categories of sources from which the personal information is collected, (iii) the business or commercial purposes for collecting or selling personal information, and (iv) the categories of third parties with whom the business shares personal information. 

If a business sells personal information, or discloses it for a business purpose, you also have the right to request that the business disclose the following with respect to the 12-month period preceding your request: (i) the categories of personal information that the business sold about you and the categories of third parties to whom the personal information was sold, and (ii) the categories of personal information that the business disclosed about you for a business purpose. 

This type of request may be referred to as a “Request to Know.”  Before we can honor a Request to Know, we need to verify that the person making it is the consumer whose personal information we have.  Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized disclosure. 

Right to Request Deletion of Personal Information

You have the right to request that a business delete any personal information that the business has collected from you.  This type of request may be referred to as a “Request to Delete.” 

Before we can honor a Request to Delete, we need to verify that the person making the request is the consumer whose personal information we have.  Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized deletion.

We are not required to delete personal information if we still need it in order to complete the transaction for which the information was collected, provide a good or service requested by you (or that we reasonably anticipate based on our relationship with you), perform a contract with you, comply with legal obligations, or accomplish any other objective recognized as an exception to the right to deletion under applicable law.

Right to Opt-Out of the Sale of Personal Information

You have the right to direct a business that sells personal information about you to third parties not to sell your personal information.  This type of request may be referred to as a “Request to Opt-Out.” We do not sell Personal Information, so we do not provide a mechanism to opt-out.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by a business for the exercise of your privacy rights under the CCPA. 

How to Submit a Request To “Know”

 

You can submit a Request to Know using this form.  Or, you can email us at privacy@rokform.com.  Emailed requests must state “CCPA Request to Know” in the subject line and include:

  • your first and last name;
  • the California county in which you reside;
  • the disclosure(s) you are requesting; and
  • the reason(s) you believe we have collected, disclosed or sold your personal information, specifically, within the past 12 months (for example, you used our website or received a communication from us)

If you are emailing a request on behalf of another consumer as their authorized representative, you must include the foregoing information about the consumer and attach to the email a copy of a power of attorney appointing you as a duly authorized representative under California Probate Code sections 4000 to 4465 or written permission from the consumer to make the request. 

 

If you prefer, you can call this toll-free number to submit your request: 1-855-765-3676.

 

After confirming receipt of your request, we’ll contact you if we need more information in order to verify it.  If we can’t verify a request, we may deny it.

 

 

How to Submit a Request To “Delete”

 

You can submit a Request to Delete using this form.  Or, you can email us at privacy@rokform.com. Emailed requests must state “CCPA Request to Delete” in the subject line and include:

  • your first and last name,
  • the California county in which you reside,
  • a clear statement that you want us to delete your personal information
  • the reason(s) you believe we have collected your personal information, specifically (for example, you used our website or received a communication from us)

If you are emailing a request on behalf of another consumer as their authorized representative, you must include the foregoing information about the consumer and attach to the email a copy of a power of attorney appointing you as a duly authorized representative under California Probate Code sections 4000 to 4465 or written permission from the consumer to make the request.

 

If you prefer, you can call this toll-free number to submit your request: 1-855-765-3676.

 

After confirming receipt of your request, we’ll contact you if we need more information in order to verify it.  If we can’t verify a request, we may deny it.

 

 

Data Security

 

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.  We encrypt all information during transmission.  All information you provide to us is stored on our secure servers behind firewalls, and we implement the services of a third party hosting company to provide backup services.  We do not store any credit card information that you may supply to us.

 

The safety and security of your information also depends on you.  Where we have given you the ability to choose a password for access to certain parts of our Website, you are responsible for keeping this password confidential.  We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure.  Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website.  Any transmission of Personal Information is at your own risk.  We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

 

For information about our third party service providers’ policies regarding data security, please see the section captioned “Third Party Services” above.

 

More Disclosures For Data Subjects In The European Economic Area

 

This sections makes additional disclosures to consumers and other data subjects in the EEA, and explains rights they may have under the GDPR.

 

Data Controller Information.

 

Rokform LLC makes decisions about how your information will be used.  Our contact information is: Rokform LLC, Attn: Privacy, 16180 Scientific, Irvine, CA 92618.  You can also contact us by email at privacy@rokform.com.

 

Lawful bases for processing

 

We may process your personal data for the purposes described above if at least one of the following grounds for processing applies:

  • Processing is necessary for us to perform a contract with you or to take steps at your request prior to entering into a contract;
  • Processing is necessary to comply with our legal obligations;
  • Processing fulfills our legitimate interests in a manner that does not outweigh your rights and freedoms.  Our legitimate interests include: protecting our Website and services against malicious intrusions and unauthorized use; maintaining and improving our Website and services; understanding how our Website and services are used; personalizing our Website and services; promoting our products and services effectively; and complying with legal obligations and protecting our legal rights.
  • Processing is necessary to protect the vital interests of you or another individual
  • You have consented to the processing

 

Automated decision making

 

We do not make any decisions involving the use of algorithms or profiling that significantly affects you.

 

Your rights under GDPR

 

The GDPR provides you with the following rights, which you can exercise by contacting us at privacy@rokform.com and using the subject line “GDPR”:

 

  • The right to request access to and rectification of your personal information.  You may obtain additional information about our processing and a copy of your stored information.  You also have the right to request that we update your information if it is inaccurate or incomplete.
  • The right to request erasure of your personal information.  You may request for us to erase your information from our systems if it is no longer necessary for the reason we collected it, or you withdraw consent and no other legal basis for processing exists.
  • The right to restrict our processing of your personal information.  You have the right to restrict our processing if: (1) you disagree with the accuracy of your information; (2) our processing is deemed unlawful and you do not want us to erase your information; or (3) we no longer need your information for the purposes for which we collected it but we must store it to comply with our legal obligations.
  • The right to data portability.  You may receive and transmit your personal information to another controller where our processing is based on consent you gave us and was carried out by automated means.
  • The right to object.  You have the right to object to our processing of your personal information where we process it because of a legitimate interest.

 

You also have the right to file a complaint with the supervisory authority of your member state.

 

International Data Transfers.

 

Rokform has its headquarters in the United States. Information we collect about you will therefore be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Commission under Article 45 of the GDPR.  To the extent we make transfers of Personal Information to third parties in the United States or other countries that have not received an adequacy finding, we rely on derogations for specific situations as set forth in Article 49 of the GDPR.  In particular, we make such transfers: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms.  We endeavor to apply suitable safeguards to protect the privacy and security of your Personal Information and to use it only consistent with your relationship with us and the practices described in this Privacy Policy.  We also endeavor to enter into data processing agreements and European Commission-approved model clauses with service providers whenever feasible and appropriate.

 

Changes to Our Privacy Policy

 

It is our policy to post any changes we make to our Policy on this page with a notice that the Policy has been updated on the Website home page.  If we make material changes to how we treat our users' Personal Information, we will notify you by email to the email address specified in your account or through a notice on the Website home page.  The date the Policy was last revised is identified at the top of the page.  You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

 

 

Contact Information

 

To ask questions or comment about this Policy and our privacy practices, please contact us:

By Mail:  Rokform LLC, Attn: Privacy, 16180 Scientific, Irvine, CA 92618.

By Electronic Mail:  privacy@rokform.com.