Under California Civil Code Section 1798.83 (known as the “shine the light” law), California residents have a right to request an information-sharing disclosure from a business to which they have provided personal information and which has disclosed the information to any third party for third-party direct marketing uses in the prior calendar year. A business may comply with this law by (i) publishing and implementing a policy that provides California residents with the choice to opt out of the sharing of their personal information for third-party direct marketing uses and (ii) informing California residents, upon receipt of their requests for an information-sharing disclosure under this law, on how to exercise their choice to opt out.
Do Not Track Disclosure: We do not currently respond to “Do Not Track” signals of web browsers. However, should the industry establish uniform technological standards for recognizing and implementing “Do Not Track” signals, we would be open to following such industry standards.2. SPECIAL NOTICE FOR PARENTS
The RadioFlyer.com website and all other Radio Flyer Services are intended for the general audience and are designed to showcase Radio Flyer products and to provide an online platform for our customers to purchase Radio Flyer products and to share comments, product reviews, stories, photos, etc. about their experiences with Radio Flyer products. The RadioFlyer.com website and other Radio Flyer Services are not directed or targeted to children under the age of 13. Radio Flyer does not knowingly collect personal information from children under the age of 13. If we discover or receive notice that any personal information we have received is provided by an underage child, we will promptly delete such information from our database. We urge parents and legal guardians to spend time online with their children and to participate in and monitor the online activities of their children.
Many areas of the Radio Flyer Services are accessible without the need for users to provide personal information to us. However, certain features do require users to submit personal information to us, such as creating an account, making a purchase, signing up for the Birthday Club, registering a product, submitting a photo, product review, story, profile, etc. for posting on the Radio Flyer Services, submitting a request or inquiry to us, entering a Radio Flyer Promotion, etc. (each, an “Identification Activity”). For those features, we have implemented an age gate in order to prevent the collection of personal information from underage users.
NOTE: Radio Flyer will only collect a child’s personally identifiable information if it is voluntarily submitted to us by the child’s parent or legal guardian. For example, to the extent a parent or legal guardian submits to us his/her child’s name, gender, birthday, photo, etc. on the Radio Flyer Services, we collect such information.
Some areas of the Radio Flyer Services allow you to post information for public viewing, such as posting a photo, comments to a blog, or a product review. Parents and legal guardians are advised to use caution when posting personal information about their children in such areas.3. TYPES OF INFORMATION WE COLLECT
3.1 Personally Identifiable Information (“PII”): This is any information that identifies a person individually, such as first and last name, email address, telephone number, physical or mailing address, credit card information, etc. Many areas of the Radio Flyer Services are accessible without the need for users to provide PII to us. However, to the extent you voluntarily provide PII to us, we collect such information. Also, when you engage in an Identification Activity, we collect PII from you in connection with such activity. Whether or not to disclose PII is completely your choice. However, without providing PII, you will not be able to engage in or complete an Identification Activity. You must be 18 or older to engage in an Identification Activity on the Radio Flyer Services.
3.2 Aggregate and Anonymous Information (“AAI”): This refers to any information that does not identify a person individually. For example, we collect anonymous group data (demographics, interests and preferences, etc.) about users of the Radio Flyer Services. We also collect user traffic data pertaining to the Radio Flyer Services, such as: total page views in a given time period; average amount of time that visitors spend on the site and on particular pages of the site; percentage of visitors from a certain geographical area, etc. Moreover, we may combine “User Activity Information” (as described below) about you and other users of the Radio Flyer Services to generate aggregate information that reflects activities, habits, preferences, interests, etc. about our users as a group. In addition, we may take PII and make it non-personally identifiable, such as by aggregating your information with information about other individuals, or by removing personally-identifiable elements (such as names) so as to “anonymize” or “de-personalize” your information.
3.3 User Activity Information (“UAI”): This refers to information we collect about user activities on the Radio Flyer Services. For example, we collect “clickstream data” for all visitors, such as IP addresses (which are numerical numbers that are automatically assigned to users’ computers and mobile devices when they are surfing the Internet), page requests, pages visited, content viewed, clicks and search queries made, etc. We may also collect user activity information on the Radio Flyer Services through cookies and web beacons (see Section 7 Cookies and Web Beacons below for more information).
NOTE: To the extent we use UAI in a manner that identifies a person individually (e.g., if we link or associate such information with name or address), such information will be treated as PII. Otherwise, UAI will be treated as AAI.4. OUR USE OF INFORMATION
As a general matter, we use information collected on the Radio Flyer Services to personalize and improve user experience, to improve customer service, to process user transactions with us, to respond to use requests and inquiries, and to communicate with users about products, services, special offers, deals, promotions, etc. that we offer.
When you provide PII to us in connection with an Identification Activity, we use the information to process, enable, and manage such activity. For example:
- If you create an account on the Radio Flyer Services, we use PII provided by you to set up, administer, service, and communicate with you regarding, your account.
- If you make a purchase on the Radio Flyer Services, we use PII provided by you to process and fulfill your transaction with us, including communicating with you regarding your purchase and providing you with customer service. NOTE: We only use customer credit card information to process payments for purchases and refunds for authorized returns, and do not use, share or retain such information for any other purpose.
- If you register a product you have previously purchased from us on the Radio Flyer Services, we use PII provided by you to verify, process, and respond to your registration request.
If you submit a photo, story, profile, product review, comment, etc. for posting on the Radio Flyer Services, we use PII provided by you to process, enable, and manage your posting.
- By submitting a photo in the “Photo Album” area of the RadioFlyer.com website, you accept and agree to be bound by Radio Flyer’s Photo Album terms and conditions published at https://www.radioflyer.com/photo-terms-conditions.
- By submitting any other material to Radio Flyer, you accept and agree to be bound by such terms and conditions published by Radio Flyer as related to such material.
- If you submit a request or inquiry to us on the Radio Flyer Services, we use PII provided by you to respond to and communicate with you regarding your request or inquiry.
- If you sign up for a Radio Flyer Promotion, we use PII provided by you to process, administer, and communicate with you regarding your participation in such promotion.
Also, by providing your contact information (email address, mailing address, telephone number, etc.) to us, you understand and agree that we may use such information:
- to contact you with marketing/promotional information about our products, services, special deals, offers, promotions, coupons, discounts, etc. that may be of interest to you (see Section 6 Information Access and Choice below for information on how to opt out of receiving marketing/promotional information from us).
We do not share PII collected from our users with third parties, except in the circumstances described below:
- When a user makes the choice to post PII publicly on the Radio Flyer Services, the information will be made available to others. Examples include a user’s voluntary posting of a personal photo in the “Photo Album” area of the RadioFlyer.com website, a user’s voluntary disclosure of PII in a publicly posted comment, product review, story, profile, etc.
- We may from time to time use certain third-party services for the operation of the Radio Flyer Services, such as purchase and credit card payment processing, order fulfillment, customer service and support, hosting and maintenance and technical support for the Radio Flyer Services, data analyses, data storage, and security. To the extent a third-party service provider needs to access PII in order to perform services to us, we share the information with that provider. We require that a third-party service provider limit its use of PII solely to providing services to us and that it maintain the confidentiality, security and integrity of such information and not make unauthorized use or disclosure of the information.
- From time to time, we may conduct a Radio Flyer Promotion with one or more third-party co-sponsors. As a condition of participation in such a promotion, we may ask for your affirmative consent (opt-in) to allow us to share your PII collected in connection with the promotion with our co-sponsor(s), with the understanding that our co-sponsor(s) may use the information for its/their own direct marketing purposes and that Radio Flyer will have no control over such use by its co-sponsor(s).
6.1 Information Access: To access and update your PII that we store in our records, please email your request to firstname.lastname@example.org. We reserve the right to verify your identity prior to honoring your request. If you have an account on the Radio Flyer Services, you can view and update your account information by going to the account profile page after logging into your account.
6.2 Deletion of Information: If you wish to delete PII that we store in our records (including cancellation of your account on the Radio Flyer Services), please email your request to email@example.com. We reserve the right to verify your identity prior to honoring your request. PLEASE NOTE:
- You understand and acknowledge that we reserve the right to retain your information if doing so is necessary to comply with law or legal process (including a court order or subpoena), to cooperate with law enforcement (including investigation of an alleged or suspected crime, fraud or other illegal activity), or to complete a pending transaction, to resolve a claim or dispute, or to enforce an applicable agreement between you and Radio Flyer.
- You understand and acknowledge that we can only delete PII that we store in our records, and will not be able to delete PII stored by third parties.
6.3 Opt-Out re. Marketing Communications from Radio Flyer: To opt out of receiving marketing/promotional information from us, please send your request via email to firstname.lastname@example.org, or via postal mail to Radio Flyer, Inc. Attn: Radio Flyer Team, 6515 W. Grand Avenue, Chicago, IL 60707. You must include your name and full address in your request to opt out. We reserve the right to verify your identity prior to honoring your request. To opt out of receiving marketing/promotional emails from us, you may also use the “unsubscribe” link provided in a marketing/promotional email you previously received from us. We will endeavor to process your opt-out request as soon as possible after receipt (or within such time as required by law).
6.4 Opt-Out of Radio Flyer’s Sharing of Your Information: If you make a purchase online or by phone from Radio Flyer after March 31, 2015 and you wish to opt out of Radio Flyer’s sharing of your Purchase Information for direct mail marketing, you may make a request using one of the following methods:
- You may send your request via email to email@example.com, or via postal mail to Radio Flyer, Inc. Attn: Radio Flyer Team, 6515 W. Grand Avenue, Chicago, IL 60707. You must include your name and full address in your request to opt out
- You may also submit your request by selecting the “Opt Out” button below and following the prompts.
So that we can properly act on your request, if via email, please be sure to include the following statement: “I wish to stop receiving further advertisements (including catalogs) through postal mail that result from Radio Flyer’s sharing of my information.” We reserve the right to verify your identity prior to honoring your request. PLEASE NOTE:7. COOKIES AND SIMILAR TECHNOLOGIES
We may also use “web beacons” (also known as “clear GIFs,” “pixel tags,” etc.) – which are small bits of code embedded in web pages or in emails – to deliver or communicate with cookies, to count users who have visited a web page, and to understand usage patterns. We may include web beacons in emails to help us recognize activities such as when an email was opened, how many times an email was forwarded, which links in the email were clicked on, etc. Web beacons cannot be declined when delivered via a regular web page. However, web beacons can be refused when delivered via email. If you do not wish to receive web beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software.
7.3 Use of Google Analytics: We may use Google Analytics to collect and analyze information about our users’ demographics and interests, in order to measure and improve the Radio Flyer Services. We may also make use of other Google Analytics for Display Advertising features, such as Remarketing, Google Display Network Impression Reporting and/or the DoubleClick Campaign Manager integration. We are required by Google to disclose the following in connection with use of any Google Analytics for Display Advertising features:
- You may opt out of Google Analytics for Display Advertising or customize Google Display Network ads by using the Google Ads Settings page at https://www.google.com/settings/ads?hl=en. You may also prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on which can be downloaded at https://tools.google.com/dlpage/gaoptout.
- If we use the Google Analytics for Display Advertising Remarketing feature, we will use such Remarketing feature to advertise online and third party vendors, including Google, may show Radio Flyer ads on sites across the Internet.
- We and third party vendors, including Google, may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to (i) inform, optimize and serve ads based on a user’s past visits to the Radio Flyer Services, and/or (ii) report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Radio Flyer Services.
- Data from Google Analytics Demographics and Interest Reporting may be utilized by us to help recognize and understand user preferences, to make improvements to the Radio Flyer Services, to choose content and advertising to display to you, and for other business purposes that will allow us to better serve you.
Generally, we retain your PII only for as long as you maintain an account or relationship with us, except that if you make a purchase with us, we will only store your credit card information for the duration of the transaction – that is, the duration needed to process, fulfill and complete your purchase, including any applicable return and refund period – and will not store the information thereafter. However, you understand and agree that we reserve the right to retain your information if doing so is necessary to comply with law or legal process (including a court order or subpoena), to cooperate with law enforcement (including investigation of an alleged or suspected crime, fraud or other illegal activity), or to complete a pending transaction, to resolve a claim or dispute, or to enforce an applicable agreement between you and Radio Flyer.
Because of the anonymous, non-personally identifiable nature of AAI, we may retain AAI indefinitely.9. INTERNATIONAL DATA TRANSFER
We use a secure server for the Radio Flyer Services and comply with the Payment Card Industry (“PCI”) data security standards for credit card transactions made on the Radio Flyer Services. When you place an order on the Radio Flyer Services, your credit card information is transmitted to us via Secure Socket Layer (“SSL”) technology and then encrypted by our online payment processing service provider, and our online payment processing service provider is required to keep your credit card information confidential and secure and not use the information for any unauthorized purpose. We do not retain your credit card information after a transaction is completed. If you wish to make another purchase in the future you will need to re-enter your credit card information.
Although we use commercially reasonable measures to safeguard your personal information, no absolute security can be guaranteed. It is important for you to protect against unauthorized access to your password and to your computer. We urge you to keep your account login information in a safe place and not to divulge it to anyone. Also, remember to sign off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place such as a library or an Internet cafe.
We will endeavor to notify you if and to the extent required by law, in the event we become aware of a breach or suspected breach of the security of your PII stored by or for us. However, we are not liable for any breach of the security of your personal information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third-party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism.11. LINKS TO THIRD-PARTY PRODUCTS AND SERVICES
Radio Flyer, Inc.
Attn: Radio Flyer Team
6515 W. Grand Avenue, Chicago, IL 60707
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