ADDENDUM TO PRIVACY POLICY FOR CONNECTICUT, DELAWARE, AND NEW JERSEY CONSUMERS
This policy supplements the information contained in our Privacy Policy and is adopted to comply with the Connecticut Data Privacy Act ("CTDPA"), Delaware Personal Data Privacy Act ("DPDPA"), New Jersey Data Privacy Act ("NJDPA"), and related regulations, as may be further amended from time to time ("CTDPA, DPDPA, NJDPA Policy"). These Policies apply solely to visitors, users, consumers and/or others who reside in the State of Connecticut, Delaware, and New Jersey ("Consumers"). Any terms defined in the CTDPA, DPDPA, NJDPA have the same meaning when used in this CTDPA, DPDPA, NJDPA Policy. All other capitalized terms shall have the same meaning as those designated in the Privacy Policy. This CTDPA, DPDPA, NJDPA Policy explains how the Company, and our subsidiaries and affiliates, ("Company," "we," "us," or "our") collect, use, disclose and retain Personal Information and how consumers may exercise their rights under CTDPA, DPDPA, or NJDPA. All references herein to the "Policy" or "Privacy Policy" shall be deemed to reference the Raymour & Flanigan Privacy Policy to which this Addendum is linked, which can be found here.
A. What Information is Collected.
The CTDPA, DPDPA, and NJDPA defines Personal Data as "any information that is linked or reasonably linkable to an identified or identifiable individual" but does not include publicly available information, or deidentified or aggregated information. The Company’s data collection practices include the collection and use of Personal Data as described in this Privacy Policy and as set forth below. This CTDPA, DPDPA, or NJDPA Policy applies to our data practices both online and offline.
The Company’s collection of Personal Data is described in Section 1 of the Privacy Policy. The categories of Personal Data we collect may include;
- Identifiers: which may include, but is not limited to name, IP address, phone number, email address, account information, social security number, driver’s license number, passport number, credit card information or similar identifiers.
- Internet or Other Electronic Network Information: which may include, but is not limited to, browsing information, search history, purchase history, information about your interaction with the Online Services or advertisement.
- Non-precise location Information
- Professional or Employment Related Information
- Inferences such as your user references and online behavior
- Sensitive Data: which may include information concerning precise geolocation. We will not collect Sensitive Data without your consent.
B. Our Purposes for the Collection and Use of Personal Data.
We may collect Personal Data directly from Consumers, users of our Online Services, affiliates, business partners, agents, Service Providers, third parties, etc. Our collection of Personal Data is limited to the business and commercial purposes as described below:
- To perform the retail services for which it was provided and to provide products to you;
- Administer and improve our Services;
- Facilitate billing, collections, and shipment;
- Contact Consumers with information on products and Services;
- Market our products and Services to Consumers. We use some Personal Data to serve you ads targeted to you interests based on your online activities. You have a Right to Opt-Out of Targeted Advertising at any time. You can submit a request to Opt-Out of Targeted Advertising by using our Consumer Request Form, found here. The Right to Opt-Out is subject to exemptions under the CTDPA, DPDPA, or NJDPA and other limitations under applicable law;
- Detect fraud or theft or for other security purposes, including to investigate complaints;
- Comply with legal, reporting, and regulatory requirements;
- Maintain, manage, and service Consumer accounts;
- Provide customer service or support;
- Verify consumer identity as necessary under applicable law;
- Send transactional communications as part of our Services;
- For other purposes that are compatible with this Privacy Policy or where permitted by applicable law; and
- In any other way we may describe when you provide the information, or for which you provide authorization.
C. Categories of Personal Data Shared with Third Parties.
The Company may disclose the categories outlined in Section A above to third parties.
D. Categories of Third Parties with Whom We Share Personal Data.
The Company discloses the categories of Personal Data outlined above and in the Privacy Policy to certain Service Providers or other third parties for business purposes, to provide our Services, or for other purposes as provided by CTDPA, DPDPA, or NJDPA. This includes: a) our affiliates b) to professional Service Providers for business operations c) information technology, software, and cloud providers, security providers, and similar services in connection with providing our Services and in the support of daily operations d) to Service Providers to support business operations e) to Service Providers to develop, operate, and maintain our Online Services f) to Service Providers for marketing purposes g) to our employees, affiliated companies, contractors, agents and third-party vendors to perform services related to your account, to offer our Services, and for business operations.
The Company may also have to disclose your information as otherwise outlined in Section 3 of the Privacy Policy.
The Company may also share your Personal Data, as defined under CTDPA, DPDPA, or NJDPA, to marketing software providers to use for Targeted Advertising as outlined in Section 6 of the Privacy Policy. The categories of Personal Data shared include your identifiers, commercial information, internet and other electronic identifiers, and inference information. The Company does not sell your Personal Data pursuant to CTDPA, DPDPA, or NJDPA. You may have the Right to Opt-Out of Targeted Advertising. For more information, see Section F below.
E. Consumer Rights under CTDPA, DPDPA, and NJDPA.
The CTDPA, DPDPA, or NJDPA provides Consumers with specific rights regarding their Personal Data, one per consumer during any twelve-month period. This Section details how your rights may be exercised.
- Consumers have the right to confirm whether or not the Company is processing Personal Data and access such Personal Data (the “Right to Access/Confirm”).
- Consumers have the right to obtain a copy of the Consumer's Personal Data maintained by the Company (the “Right to Data Portability”).
- Consumers have the right to correct inaccuracies in the Consumer's Personal Data (the “Right to Correct”) maintained by the Company.
- Consumers have the right to request deletion of Personal Data, subject to certain exceptions (the “Right to Delete”). Once we receive a request and confirm the Consumer’s identity, we will review the request to determine if an exception allowing us to retain the information applies.
- Consumers have the right to opt out of the processing of Personal Data for purposes of Target Advertising (the "Right to Opt-Out"). To exercise this right, please visit our Consumer Request Form, found here.
F. How To Exercise Rights Under CTDPA, DPDPA, or NJDPA.
Connecticut, Delaware, or New Jersey Consumers or their authorized agents may submit a request through our Consumer Request Form, found here.
If you’re making a request as an Authorized Agent, please submit the Authorized Agent Request Form, found here which requires a notarized statement that you are authorized to make the request on behalf of the Consumer. We may also require other identity confirmation.
When submitting a request under CTDPA, DPDPA, or NJDPA, we are required to reasonably Authenticate your request to appropriately secure Personal Data. If we cannot authenticate the request, we will notify the requestor that we are unable to fulfill the request. We will only use Personal Data provided in the request to verify the requestor's identity or authority to make it. We endeavor to respond to an authenticated consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period. We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will detail why we made that decision and provide a cost estimate before completing the request. If you have any other questions regarding this process, please contact us.
If you disagree with the Company’s refusal concerning a consumer request, you have the right to appeal the decision by submitting an appeal through the Consumer Request Form, found here. Within sixty (60) days after receipt of an appeal, Company shall inform you, in writing, of any action taken or not taken in response to the appeal, including an explanation of Company’s decision. .
G. Updates to this CTDPA, DPDPA, NJDPA Policy.
Please refer to this CTDPA, DPDPA, NJDPA Policy regularly as it may be revised due to legislative changes, changes in technology or our privacy practices or new uses of Personal Data not previously disclosed in this CTDPA, DPDPA, NJDPA Policy. Revisions are effective upon posting. If you have any comments, concerns, or questions about this CTDPA, DPDPA, NJDPA Policy, please contact us.
H. Contact Us.
If you have any questions or need to contact us, please email us at compliance@raymourflanigan.com. If you would like to submit a consumer request, please use our Consumer Request Form, found found here.