Privacy Policy

Privacy Policy

Introduction

E. Formella & Sons values its visitors’ privacy. This privacy policy is effective 1/1/2016; it summarizes what information we might collect from a registered user or other visitor (“you”), and what we will and will not do with it.

Please note that this privacy policy does not govern the collection and use of information by companies that E. Formella & Sons does not control, nor by individuals not employed or managed by E. Formella & Sons. If you visit a web site that we mention or link to, be sure to review its privacy policy before providing the site with information.

What we do with your personally identifiable information

It is always up to you whether to disclose personally identifiable information to us, although if you elect not to do so, we reserve the right not to register you as a user or provide you with any products or services. “Personally identifiable information” means information that can be used to identify you as an individual, such as, for example:

•your name, company, email address, phone number, billing address, and shipping address

•your E. Formella & Sons user ID and password

•credit card information (In some cases credit card information is handled by a payment processor and not stored on our systems)

•any account-preference or transaction information you provide us

•your computer’s domain name and IP address, indicating where your computer is located on the Internet

•session data for your login session, so that our computer can ‘talk’ to yours while you are logged in

If you provide personally identifiable information to us, either directly or through a reseller or other business partner, we will not sell or rent it to a third parties without your permission. However, unless you opt out (see below), we may use your contact information:

•to send you e-mail newsletters or promotions. You can opt out at any time by clicking here or by e-mailing kathy.formella@formella.com with subject line “unsubscribe”

•to provide you with information we believe you need to know or may find useful, such as (for example) news about our services and products through a concept called “Remarketing” (Showing you ads for our products on other sites you may visit)

•To tell you about modifications to the Terms of Service;

•To authorize and capture funds through a credit card processor or gateway

•To send and receive information necessary for product shipping and freight, including tracking numbers etc.

•To update our CRM so we maintain accurate contact information for our customers and prospects. We will:

•take commercially reasonable precautions to protect the information from loss, misuse and unauthorized access, disclosure, alteration and destruction;

•aggregate with other information in such a way so that your identity cannot reasonably be determined (for example, statistical compilations, hashing etc.);

•cooperate with law enforcement, for example, in response to a subpoena or search warrant;

•utilize aggregate visitor/customer data with third party consultants for analytics purposes.

•protect the rights, safety, or property of E. Formella & Sons, its users, or others; this may include (for example) exchanging information with other organizations for fraud protection and/or risk reduction.

Collection of Data for Re-marketing

Our site uses technologies of third-party partners such as NextRoll to help us recognize your device and understand how you use our site(s) so that we can improve our services to reflect your interests and serve you advertisements about the products and/or services that are likely to be of more interest to you. Specifically, NextRoll these partners collect information about your activity on our site(s) to enable us to:

•measure and analyze traffic and browsing activity on our site(s);

•show advertisements for our products and/or services to you on third-party sites;

•measure and analyze the performance of our advertising campaigns;

•share data, such as hashed email derived from emails or other online identifiers collected on our site(s) with NextRoll advertising partners. This allows our partners to recognize and deliver you ads across devices and browsers. To read more about the technologies used by NextRoll and their cross device capabilities please refer to NextRoll’s Privacy Notice.

Opting-Out

Our partners [such as NextRoll] may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason you can use the following third party tools to decline the collection and use of information for the purpose of serving you interest based advertising:

•The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

•The EDAA’s opt-out platform http://www.youronlinechoices.com/

•The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

Other information we collect

We may collect other information that cannot be readily used to identify you, such as (for example) the domain name and IP address of your computer. We may use this information, individually or in the aggregate, for technical administration of our Web site(s); research and development; customer- and account administration; and to help us focus our marketing efforts more precisely.

Cookies

E. Formella & Sons uses “cookies” to store personal data on your computer. We may also link information stored on your computer in cookies with personal data about specific individuals stored on our servers. If you set up your Web browser (for example, Internet Explorer or Firefox) so that cookies are not allowed, you might not be able to use some or all of the features of our Web site(s).

External data storage sites

We may store your data on servers provided by third party computers or data centers with whom we have contracted.

Your privacy responsibilities

To help protect your privacy, be sure:

•not to share your user ID or password with anyone else;

•to log off the E. Formella & Sons web site when you are finished;

•to take customary precautions to guard against “malware” (viruses, Trojan horses, bots, etc.), for example by installing and updating suitable anti-virus software.

For California Residents Only

This section supplements the information contained in this Service Privacy Notice and applies solely to visitors, users, and others who are residents of the State of California, as defined in Section 17014 of Title 18 of the California Code of Regulations. This section is effective as of January 1, 2020, to comply with the California Consumer Privacy Act of 2018 (“CCPA”).

Any terms defined in the CCPA have the same meaning when used in this section.

Information We Collect and the Purposes for Which this Information is Used

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). This collection of information is listed in What Data We Collect.

We set out below the CCPA categories of personal information we have collected from consumers within the last twelve (12) months in respect of our Services. Please note that personal information in certain categories may overlap with other categories.

Category
Collected
Details
Source

A. Identifiers Yes Device IP address, email address, cookie string data, pseudonymous data (e.g. hashed emails), operating system, and (in the case of mobile devices) your device type, and mobile device’s identifier (such as the Apple IDFA or Android Advertising ID) and any other unique identifier that may be assigned to any device by third parties and cross-referenced to recognize a device.  Directly and indirectly from consumers, third party data providers and Advertising Partners. In the case of business email addresses, RollWorks B2B Services may infer a business email address. 

B. Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))  Yes In respect of RollWorks B2B Services:

 Name, business address, business telephone number, education, employment and employment history.

In respect of AdRoll D2C Services:

 The perceived general education level of consumers may be collected for D2C marketing, advertising and analytics to the extent relevant for providing marketing or advertising.

 Directly from third party data providers. 

C. Protected classification characteristics under California or federal law  Yes  Limited to age ranges such as 35-44, 45-54, 55-64 and 65+ and male/female gender categories are sometimes collected for use of AdRoll’s D2C Services that do not carry a risk of unintended discrimination.  From third party data providers. 

D. Commercial information  Yes  Records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.  Directly from consumers and Advertiser. 

E. Biometric information  No  –  – 

F. Internet or other similar network activity  Yes  Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. For example, which pages you visited and when, what items were clicked on a page, how much time was spent on a page, whether you downloaded a white paper on a B2B website, what items you placed into your online shopping cart, what products were purchased and the price of the products purchased.  Directly from cookie browsing history on Advertisers’ Digital Properties. Non-personal information about one of our ads e.g. the third party who served the ad, and the name of the ad) may be connected with browsing history or activity on our websites for the purposes of determining attribution information (e.g. whether particular ad led to a consumer visiting our website, and, if so, which particular ad campaign). 

G. Geolocation data  Yes  Non-precise geolocation derived from IP address.  Directly from consumers and Advertising Partners. 

H. Sensory data  No  –  – 

I. Professional or employment-related information  Yes  In respect of RollWorks B2B business only:

 Current or past job history, including details about the employer (industry, name, company location, company domain or URL), and employee (positions held, duration of employment, and office location of the company where the employee worked).  Third party data providers. 

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R Part 99))  No  –  – 

K. Inferences drawn from other personal information  Yes  Creating profiles that reflect consumer preferences and interests.  Third party data providers. 

For clarity, under CCPA personal information does not include:

•Publicly available information from government records;

•De-identified or aggregated consumer information; and

•Information excluded from the CCPA’s scope such as: ◦health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and

◦personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Purposes for Which Personal Information is Collected

NextRoll is a marketing and advertising technology company. All data we collect is for the business purpose of providing services primarily for our marketing, advertising or analytical Services. However, as part of performing these Services, we also use data collected (as identified above) for the following additional business purposes:

Auditing Interactions with Consumers: count ad impressions and verify the quality of ad impressions served to unique visitors identified by cookie id or other unique identifier;

Debugging and Repair: the identification and repair of impairments to intended and existing functionalities in our Services and NextRoll Technology, perform debugging and related activities to repair errors that impair the functionality of our Services;

Security: detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities;

Internal Research and Development: conduct internal research for technological development of our Services and demonstration of the performance of these Services; and

Quality and Safety Maintenance and Verification: verify the quality or safety of our Services and improve, upgrade or enhance our Services and NextRoll Technology we provide.

For more information on how we use this data, please refer to How We Use the Data We Collect.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose (as set out above) or sell your personal information, subject to your right to opt-out of those sales (See Personal Information Sales Opt-In Rights).

The Data Sharing section sets out the personal information that we share with third parties.

Disclosure of Personal Information for a Business Purpose

With the exception of our RollWorks B2B Contact Data, NextRoll’s Services do not amount to a sale of personal information. Instead, NextRoll discloses personal data for business purposes, primarily to perform its advertising, marketing and analytical Services, but also for the purposes set out as items (1), (2) and (3) in the Purposes for which Personal Information is Collected above.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for our business purposes:

•Category A: Identifiers

We disclose your personal information for a business purpose to the categories of third parties set out in Data Sharing.

Sales of Personal Information

In the preceding (12) twelve months, pursuant to our RollWorks B2B Contact Data Service, we have sold personal information in the form of business emails from Category A (Identifiers).

Other than our RollWorks B2B Contact Data Service, we do not consider that our Services constitute a ‘sale of personal information’ under the CCPA. Instead, in the course of providing our Services, we disclose personal information for business purposes.

However, we aim to provide consumers with control over the collection and use of their personal information. Consistent with this goal, we will honor requests from consumers to “opt-out” of the collection and disclosure of their personal information. Your Rights and Choices section below provides instructions on how to opt-out of our collection and disclosure of personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes the rights of California residents under CCPA and provides information on how to exercise those rights.

Right to Know and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

•The categories of personal information we collected about you;

•The categories of sources for the personal information we collected about you;

•Our business or commercial purpose for collecting or selling that personal information;

•The categories of third parties with whom we share that personal information;

•The specific pieces of personal information we collected about you (otherwise known as a data portability request); and

•Two separate lists where we have sold or disclosed your personal information for a business purpose: ◦Sales: identifying the personal information categories that each category of recipient purchased; and

◦Disclosures for a business purpose: identifying the personal information categories that each category of recipient obtained

Right to Delete

You have the right to request that we delete any of your personal information that we collect from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Right to Know, Data Portability and Right to Deletion), we will delete (and direct our services providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

•Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relations with you or otherwise perform our contract with you;

•Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for such activities;

•Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided by law;

•Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);

•Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;

•Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

•Comply with a legal obligation; and

•Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Right to Know, Data Portability and Right to Deletion

To exercise the access, data portability, and deletion rights described above, please submit verifiable consumer request to us by either:

•Calling us at 1-844-740-7126; or

•Visiting this webpage.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable request for access of data portability twice within a 12-month period. The verifiable consumer request must:

•Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

•Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; and (ii) confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

As mentioned above in Sales of Personal Information, we have elected to honor sale opt-out rights. Please see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We will deliver our written response to you electronically unless you indicate delivery to be by mail.

Any disclosures we provide to you will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot complete a request, if applicable. Please note that personal information deleted during this period as set out in Data Retention will not be provided.

The format of our responses to you concerning personal information collected, disclosed or sold will be provided in a readily useable format that should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out Rights

To exercise the right to opt-out of our sale of your Contact Data or to opt out of interest-based advertising, you (or your authorized representative) may submit a request to us by visiting the Do Not Sell My Personal Information webpage.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

•Deny you goods or services;

•Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

•Provide you a different level or quality of goods or services; or

•Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes to this Service Privacy Notice

We may update or modify this Service Privacy Notice at our discretion and at any time. When we make changes to this Service Privacy Notice, we will post the updated notice online and update the notice’s effective date. Please review this Service Privacy Notice periodically.

If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.

Contact Us About Questions

If you have any questions about this Service Privacy Notice or our privacy practices, you can contact support@nextroll.com.

If you are located in a European Territory then, where we process your data as a data controller, NextRoll Limited is the data controller of your information. To contact NextRoll Limited please email support@nextroll.com or write to us at the following address:

NextRoll Limited
Attn: Privacy
Level 6
1, Burlington Plaza
Burlington Road
Dublin 4, Ireland

If you wish to escalate your inquiry after contacting the support team, you are welcome to contact our Data Protection Officer at dpo@nextroll.com

Lucid Privacy Group
NextRoll Data Protection Officer
1050 Page Street
San Francisco, CA 94117
USA

Notice to European Union users

E. Formella & Sons‘s web site and e-mail operations are located primarily in the United States, India and Venezuela. If you provide information to us, the information will be transferred out of the European Union (EU) to the other countries. By providing personal information to us, you are consenting to its storage and use as described herein.

Information collected from children

You must be at least 13 years old to use E. Formella & Sons‘s web site(s) and service(s). E. Formella & Sons does not knowingly collect information from children under 13. (See the U.S. Children’s Online Privacy Protection Act.)

Changes to this privacy policy

We reserve the right to change this privacy policy as we deem necessary or appropriate because of legal compliance requirements or changes in our business practices. If you have provided us with an email address, we will endeavor to notify you, by email to that address, of any material change to how we will use personally identifiable information.

Questions or comments?

If you have questions or comments about E. Formella & Sons’s privacy policy, send an email to kathy.formella@formella.com, or contact us via any of the ways described in the About Us page at URL of E. Formella & Sons www.formella.com