Privacy Policy

Roth Corporation Website Privacy Policy

EFFECTIVE DATE: April 19, 2023

At Roth Corporation (“Roth”), we value our community. We believe in transparency and are committed to being upfront about our privacy practices. 

In this Roth Corporation Website Privacy Policy (this “Policy”), we describe what information we gather about you, what we use that information for, and who we share that information with, when you visit or use our website located at www.rothliving.com, our online services, and the software provided on our website or in connection with our services (collectively the “Site”). Among the reasons that Roth collects personal information from people who visit or use the Site is to provide better services to all users of the Site.

This Policy is designed to assist you in understanding and making informed decisions when using the Site about how personal information about you may be obtained, used, shared, and disclosed to third parties by Roth. This Policy also describes how you can opt out of some uses of your personal information. 

This Policy, together with the Terms of Use Agreement posted on the Site, sets forth the general rules and policies governing your use of the Site. Depending on your activities when visiting the Site, you may be required to agree to additional terms and conditions. 

IF YOU ARE A RESIDENT OF CALIFORNIA, COLORADO, CONNECTICUT, UTAH OR VIRGINIA, THEN THERE ARE SPECIAL PROVISIONS OF THIS WEBSITE PRIVACY POLICY THAT APPLY TO YOU. THESE SPECIAL PROVISIONS ARE CONTAINED IN THE “SUPPLEMENTAL PRIVACY POLICY AND NOTICE FOR RESIDENTS OF CALIFORNIA, COLORADO, CONNECTICUT, UTAH AND VIRGINIA,” ATTACHED AS EXHIBIT 1 BELOW.  WHEN YOU ACCESS THE SITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES THAT MAY BE SUBSEQUENTLY MADE TO THIS PRIVACY POLICY, YOU SHOULD IMMEDIATELY STOP ACCESSING THE SITE.

1. CHANGES TO THIS PRIVACY POLICY

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time in our sole discretion. To let you know when we make changes to this Policy, we will amend the Effective Date. The new modified or amended Policy will apply from that new Effective Date, so please be sure to check back periodically. Your continued use of the Site after any change to this Policy will constitute your acceptance of the changes. Roth will not use your personally identifiable information, in a manner that is materially different than what was stated at the time it was collected, without your consent.  

2. THE TYPE OF INFORMATION WE COLLECT AND HOW IT IS USED

“Personal information” is information that may be used to specifically identify or contact you, such as your name, postal address, email address, and telephone number, among other things. When you visit the Site, personal information about you is not collected unless you voluntarily provide it. If you provide personal information to us, Roth might receive additional information about you from other sources and combine that additional information with the personal information that you have provided. If you communicate through the Site, the content of your communications, and your e-mail address, along with any responses from the Site, may be retained.

In certain circumstances, Roth may request, or may allow or otherwise provide you an opportunity to submit, your personally identifiable information in connection with a feature, program, promotion or some other aspect of the Site. For example, you may: (i) provide your name, mailing/shipping address, email address, and phone number when registering with the Site or using services offered through the Site; or (ii) provide personal information when you post a product or services rating or recommendation on the Site. Certain information may not be personally identifiable when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and name). Whether or not you provide this information is your choice; however, in many instances this type of information may be required to participate in a particular activity, realize a benefit that the Site may offer, or gain access to certain content on the Site.

The personally identifiable information that you submit to Roth is generally used to carry out your requests, respond to your inquiries, or better serve you, or is used in other ways naturally associated with the circumstances in which you provided the information. Roth may use this information to contact you later for a variety of reasons, such as for customer service, to provide you with information or services, or to process transactions that you have requested or agreed to receive. We may use this information to provide you with marketing or promotional information for products or services of Roth or of Roth’s parent company, subsidiaries or other affiliated companies. We may use this information to communicate with you about content or other information that you have posted or shared with Roth via the Site, or with other users of the Site, or with service providers who use the Site. We may use this information with regard to your use of the Site and, in the discretion of Roth, with regard to changes to the Site or Site policies. We may also use this information for internal business purposes, or for purposes disclosed at the time you provide your information, or as otherwise set forth in this Policy. You may opt out from receiving future promotional information from Roth, or direct that Roth not share your information in the future with any affiliated companies or third parties for their direct marketing purposes. To opt out of receiving promotional offers simply unsubscribe via the email sent for that purpose.     

In certain instances, Roth may also share your personally identifiable information with its third-party vendors who use the Site or who are performing functions on behalf of Roth, or on behalf of affiliated companies of Roth (e.g., vendors that process credit card orders, deliver merchandise, administer promotions, provide marketing or promotional assistance, analyze data, assist with customer service, and the like). In addition, Roth may share your personally identifiable information with participating sponsors of a program or promotion, and with third parties who assist Roth in using the content or other information that you have posted or shared with Roth via the Site. Further, Roth may share your personally identifiable information with third parties such as promotional partners of Roth, and persons or companies with whom Roth has marketing or other relationships, among others.

“Non-personal information” is information about you or your activities through which you cannot be personally identified. When you visit the Site, we may collect such information. Examples include the type of browser and operating system you are using, the type of device you are using, the domain name of your Internet service provider, the pages you visit on the Site and how long you spend on each page, and the unique number assigned to your computer or Internet connection. This type of information can include certain personally identifiable information that has been de-identified (i.e., information that has been rendered anonymous). Roth and its third- party service providers may obtain non-personal information about you from information that you provide, either separately or together with your personally identifiable information. This type of information may be used for a variety of purposes, including monitoring use of and improving the Site, as well as for internal analysis.

The Site may utilize a standard technology called “cookies,” described in more detail below, to provide the Site’s personalization feature, and web server logs to collect information about how the Site is used. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at the Site, and other websites visited just before your visit to the Site. This information may be collected on an aggregate basis. None of this information may be associated with you as an individual.

Non-personal information is used in a variety of ways, including to help analyze Site traffic, to understand customer needs and trends, to carry out targeted promotional activities, and to improve the services provided by Roth. Roth may use your non-personal information by itself, or we may aggregate it with information that Roth has obtained from others. Roth may share your non-personal information with its affiliated companies and third parties to achieve these objectives and others; however, this information is anonymous information that does not personally identify you. Roth may provide data analyses and certain non-personal information to third parties (who may in turn use this information to provide advertisements tailored to your interests), but this will not involve disclosing any of your personally identifiable information.

3. INFORMATION YOU PROVIDE ABOUT THIRD PARTIES

If you send another Site user or someone else a communication from the Site, as when you send Site content to a business, supplier, service provider, friend, or other person, the information you provide (names, email addresses, etc.) may be used to facilitate the communication and may not be used for any other marketing purpose unless Roth obtains consent from that person or Roth explicitly states otherwise. Please be aware that when you use any “send to” functionality on the Site, your email address may be included in the communication sent.

4. INFORMATION FROM THIRD PARTIES ABOUT YOU

Roth also may, from time to time, supplement the information we collect with outside records from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you opportunities to purchase products or services that we believe may be of interest to you. Roth may combine the information we receive from those other sources with information we collect through the Site. In those cases, Roth will apply this Policy to any personally identifiable information received, unless otherwise specifically disclosed by Roth at the time you provide your personally identifiable information.

Roth is affiliated with other businesses and works closely with them. These businesses may offer promotions or may sell items or services to you through Roth’s services. Roth may also provide services or sell products jointly with affiliated businesses. Due to the nature of our business model, when an affiliated business is associated with your transaction, we may share information that is related to such transaction with that affiliated business. Roth may share aggregated demographic information with business partners.

5. INFORMATION ABOUT SITE USE 

In addition to any personally identifiable information or other information that you choose to provide to Roth via the Site, Roth and its third-party service providers may use a variety of technologies, now and hereafter devised, that automatically collect certain Site usage information whenever you visit or interact with the Site. This information may include your browser type, your operating system, the page served, the time, the source of a request, the preceding pages viewed by you, and other similar information. Roth may use this usage information for a variety of purposes, including to enhance or otherwise improve the Site. In addition, Roth may also collect your IP address or some other unique identifier for the particular device you use to access the Internet, as applicable (collectively, referred to herein as a “Device Identifier”). A Device Identifier is a number that is automatically assigned to your computer, and Roth may identify your device by its Device Identifier. When analyzed, usage information helps Roth determine how the Site is used, such as what types of visitors arrive at the Site, what type of content is most popular, what type of content you may find most relevant, and what types of visitors are interested in particular kinds of content and advertising. Roth may associate your Device Identifier or Site usage information with the personally identifiable information you provide and may treat the combined information as personally identifiable information. Site usage information may be collected using various methods, such as web beacons, cookies, mobile device identifiers, and embedded scripts, among other methods.

1. COOKIES—IN GENERAL

We use cookies and other tracking mechanisms to track information about your use of our Site and our products and services. We may combine this information with other personal information we collect from you. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and our products and services, while others are used to enable a faster log-in process or to allow us to track your activities with respect to our Site and our products and services. Some cookies are used to enable certain functions of the Site, and some are used to store your preferences. We may use cookies to remember information that changes the way the Site or our services behave or look. Some of the cookies we use are necessary to enable you to move around the Site and use its features, including accessing secure areas that may contain content for registered users. We may use accounts-related cookies to authenticate users and prevent fraudulent use of user accounts. We may use analytics cookies to track information about how the Site and our products and services are used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, or features, or new functionality of the Site and our services, to see how our users react to them. In addition, we may use web beacons or tracking pixels to count visitor numbers, and performance cookies to track how many individual users access the Site, and how often. This information is used for statistical purposes only and it is not our intention to use such information to personally identify any user. However, if you have registered and signed into the Site, we may combine this information with information from our web analytic services and cookies to analyze in more detail how you use the Site. In addition to our own cookies, we may also use various third-party cookies to report usage statistics for the Site and our products and services, to deliver advertisements on and through the Site, and so forth. Cookies may be used to create profiles of our users, based on the user information we collect, and cookies may enable users’ identification across multiple websites. You can find more detailed information about cookies and how they work at http://www.aboutcookies.org/. Cookies may include session cookies and persistent cookies.  

1. SESSION COOKIES

Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session, or while you are logged into the Site. This allows us to process your online transactions and requests and to verify your identity, after you have logged in, as you move through our Site.

1. PERSISTENT COOKIES

Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

1. DISABLING COOKIES

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The “Help” or “Options” portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you visit our Site and disable cookies, you will be able to browse certain areas of the Site, but some features may not function, you may not be able to store your preferences, and some of our pages may not display properly. Be aware that any preferences you have set will be lost if you delete all cookies, including your preference to opt out from cookies, as this itself requires an opt-out cookie to have been set. 

1. YOUR CONSENT TO THE USE OF COOKIES

By using the Site or purchasing or using any of our products or services, and by consenting to the terms of this Policy, you consent to our use of cookies.

6. CHOICE AND CONTROL

We know our members of our community value having control over their own information, and therefore Roth gives you the choice of providing, editing or removing certain information. You may change or correct your Roth account information (except your username). For various reasons, we may contact you about our services or your activity.

7. INFORMATION SHARING AND DISCLOSURE

Roth will share personal information with companies, organizations or individuals outside of Roth if we have a good-faith belief that access, use, preservation or disclosure of such personal information is reasonably necessary to: (i) meet any applicable law, regulation, legal process or enforceable governmental request; (ii) enforce applicable provisions of the Terms of Use Agreement posted on the Site, including investigation of potential violations; (iii) detect, prevent, or otherwise address fraud, security or technical issues; and (iv) protect against harm to the rights, property or safety of Roth, Site users, or the public as required or permitted by law. 

It is not our policy to sell or rent your personal information to unaffiliated third parties. Your personal information may be shared by us with unrelated third parties, including contractors that provide services to the Site. When we share your personal information with a third party with whom we have a contractual relationship, we use reasonable efforts to include clauses in our contract with such third party that require them to comply with the privacy laws and regulations relevant to that information, and to restrict the use to the purposes for which it was provided to them.

8. OTHER USES

For security reasons, Roth does not recommend that you send non-public personally identifiable information, such as passwords, social security numbers or bank account information, to us by email. Roth may communicate with you by email in the following circumstances: (a) when you request a particular service or sign up for a feature that involves email communications; (b) when our email to you relates to requests you have made from or through Roth (e.g., product/services updates, customer support, etc.); (c) when Roth is sending you information about products and services; (d) when you have consented to being contacted by email for a particular purpose; (e) when you send Roth an e-mail, post information on the Site, or otherwise submit information to Roth electronically, where Roth may email you to follow up or otherwise communicate with you with respect thereto; (f) when we provide you with legal notices or notices with respect to your use of the Site; or (g) when we are otherwise attempting to facilitate a transaction between you and Roth, or between you and someone else. In certain instances, Roth may provide you with tools on the Site that will allow you to set your preferences for receiving email communications from Roth or other persons, where such tools allow you to agree to some communications but not others. You may opt out of receiving future commercial email communications from Roth by sending an email to Roth opting out of future promotional email communications; provided, however, that Roth reserves the right to send you transactional emails, such as customer service communications and auto-renewal billing notices. 

9. DO-NOT-TRACK DISCLOSURE

Currently, our systems do not recognize browser “do-not-track” requests. 

10. EXCEPTIONS TO THIS PRIVACY POLICY

This Policy applies to all of the services Roth offers. It excludes services that have separate privacy policies that do not incorporate this Policy. Furthermore, it does not apply to services offered by other companies or individuals, including products, services, or sites that may be displayed to you on the Site, or other websites linked from the Site. This Policy does not cover the information practices of other companies and organizations who advertise on and or provide services through the Site, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Regarding the Site’s links to other websites, neither Roth nor any third parties that help us operate the Site are responsible for the information collection or privacy practices of such other websites. You should consult the privacy policies of other websites before you visit those websites or provide any personal information to those websites. Roth or third parties that help us operate the Site may provide information at the Site about programs and events that are sponsored by or co-sponsored by other firms or organizations. If you register for any of these programs or events, then Roth and third parties that help us operate the Site may have no control over the use of your personal information by such other firms or organizations.

Third-party applications may be available via the Site. The owners of these applications (“Third-Party Owners”) may collect personally identifiable information from you and may have their own policies and practices. Roth is not responsible for how Third-Party Owners, or their applications use your personally identifiable information. Such Third-Party Owners may have their own terms of service, privacy policies or other policies, and may ask you to agree to the same. Roth is not responsible for those policies or for the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application, or otherwise interacting with it.

Roth and third parties that help us operate the Site reserve the right to disclose your personal information: (i) if it is believed that the Site is being used to commit unlawful acts; (ii) if disclosure of your personal information is required to comply with applicable laws or regulations or with a court or administrative order, or will help to enforce any applicable terms of use; and (iii) to protect your safety and security, including the safety and security of property that belongs to you, or to protect the safety and security of the Site or of third parties.

11. SECURITY

Although the Site employs security measures that are reasonably appropriate to protect your personal information, neither Roth nor any third party that helps us operate the Site guarantees that such security precautions will protect against the loss or misuse of your personal information. Similarly, neither Roth nor any third party that helps us operate the Site guarantees the privacy of personal information that you transmit over the Internet or that may be collected in transit by others, including contractors that provide services to Roth or to third parties that help us operate the Site. 

By using the Site, you agree that you understand the foregoing provisions of this section, and you consent to the transfer of your personal information across national borders, and to the storage and processing of your information in a country that may not provide the same level of privacy protection that your country provides.

12. CHILDREN’S PRIVACY

Roth does not intend the Site or our products or services to be used by individuals under the age of 18. Roth relies upon parents or guardians 18 years of age or older to determine if the Site and our products and services are appropriate for viewing, access, or participation by individuals under the age of 18. If an individual under the age of 18 uses the Site or any of our products or services, such individual may only do so under the supervision of a parent or guardian who is 18 years of age or older.

We do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.

13. CONTACT US

If you have any questions regarding this Policy you may send an email to  ______________________ or write to:

Roth Corporation

742 S. Broadway

Denver, CO 80209  

Exhibit 1:

Supplemental Privacy Policy and Notice 
for Residents of 
California, Colorado, Connecticut, Utah and Virginia

This Supplemental Privacy Policy and Notice (“Supplemental Policy”) applies only to information collected about persons residing in California, Colorado, Virginia, Utah, or Connecticut, and supplements the information contained in the Roth Corporation Website Privacy Policy. It provides information required under the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), the Colorado Privacy Act of 2021 (the “CPA”), the Connecticut Data Privacy Act of 2022 (“CDPA”), the Virginia Consumer Data Protection Act of 2021 (the “VCDPA”), and the Utah Consumer Privacy Act of 2022 (the “UCPA”); and any and all regulations arising therefrom.

This Supplemental Policy describes Roth Corporation practices regarding the collection, use, and disclosure of Personal Information and provides instructions for submitting data subject requests. Some portions of this Supplemental Policy apply only to consumers of particular states, and we have indicated where those portions are state-specific.

If you are unable to review or access this Supplemental Policy due to a disability, you may contact us at ___________________ to access this Supplemental Policy in an alternative format.

1. DEFINITIONS SPECIFIC TO THIS SUPPLEMENTAL POLICY

“Consumer” means a natural person who resides in California, Colorado, Connecticut, Virginia, or Utah and to whom we offer information, goods, or services. For purposes of this Supplemental Policy, this term includes natural persons who reside in California and engage with us (i) as part of business-to-business transactions, or (ii) as employees, job applicants, officers, directors, or independent contractors.

“Disclosed for a Business Purpose” means, with respect to a Consumer’s Personal Information, that the Personal Information is disclosed by us to a Third Party or Vendor, for our operational purposes, or for the operational purposes of the Third Party or Vendor, where such operational purposes may include data auditing, data security, debugging, nonpersonalized advertising, research for technological development, improving and upgrading our services, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information includes “personal data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA. Personal Information also includes “Sensitive Personal Information,” as defined below.

“Sensitive Personal Information” means Personal Information that reveals a Consumer’s: 1) Social security, driver’s license, state identification card, or passport number; 2) Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to the individual’s account; 3) Precise geolocation; 4) Racial or ethnic origin; 5) Religious beliefs; 5) Union membership; 6) Contents of email or text messages, unless we are the intended recipient; 7) Genetic data; 8) Biometric information used to uniquely identify the Consumer, and 9) Health, sex life, or sexual orientation. Sensitive Personal Information also includes “sensitive data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA.

“Shared” means, with respect to a Consumer’s Personal Information, that the Personal Information is shared, rented, released, disclosed, disseminated, made available, transferred, or otherwise communicated orally, in writing, or by electronic or other means, by us to a Third Party for cross-context behavioral advertising.

“Third Party” means a person or organization which is not a Consumer, Vendor, or an entity owned or controlled by us and as defined by the CCPA, CPA, VCDPA, UCPA, and CDPA.

“Vendor” means a “contractor,” “processor,” or “service provider,” which collects, stores, or otherwise handles data for us, as those terms are defined in the CCPA, CPA, VCDPA, UCPA, and CDPA.

Other terms used in this Supplemental Policy may be defined under the CCPA, CPA, VCDPA, UCPA, or CDPA, and they shall have the meanings described in those statutes. If there are variations between such definitions in different laws, you will be covered by the definition that applies in your state. For example, if you are a Virginia consumer, terms defined in the VCDPA shall apply to you if they are used in this Supplemental Policy.

2. THE PERSONAL INFORMATION WE COLLECT AND DISCLOSE

The chart below shows the categories of Personal Information that we have collected about Consumers in the preceding 12 months; examples of Personal Information in each category; the types of sources from which each category of Personal Information is collected; the Business Purposes for which each category of Personal Information is collected and Disclosed; and the types of Vendors or Third parties to or with whom each category of Personal Information is Disclosed for a Business Purpose. 

As this chart shows, we may Disclose certain Personal Information to Third Parties or Vendors for Business Purposes. We do not sell or Share (as defined in Section 1 above) your Personal Information with Third Parties.

 

Category of Personal Information Collected in the Preceding 12 Months	Examples	Sources from Which This Personal Information is Collected	Business Purposes for Collecting and Sharing or Disclosing this Personal Information	Types of Vendors or Third Parties to or with Whom this Personal Information has Been Disclosed for a Business Purpose in the Preceding 12 Months
Unique Identifiers	real name, signature, alias, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, insurance policy number, advertising ID, loyalty or gift card ID, or other similar identifiers	-Directly from you by telephone, our websites, our mobile apps, in person -Social media [-Other individuals -Rewards programs -Analytics providers -Vendors -Franchisees -Business partners]	-Provide information, products and services -Security, credit or fraud prevention -Provide customer service and assess satisfaction -Personalize customer experience -Improve products and services -Improve marketing and customer communications -Comply with legal requirements	Disclosed: -Vendors -Stored value account administrator -Affiliates Shared or Sold: -None
Contact and Financial Information	Name, address, telephone, email, credit card number, debit card number, or any other financial information	-Directly from you by telephone, our websites, our mobile apps, in person	-Complete transactions -Other services and discounts -Process claims -Prevent fraud -Track purchase history	Disclosed: -Card processor -Vendors -Stored value account administrator -Affiliates Shared or Sold: -None
Characteristics of Protected Classifications	Race, color, ancestry, national origin, sexual orientation, gender identity and expression, sex, pregnancy, childbirth & related medical conditions, religion, disability, age (for persons 40 and older), military or veteran status, status as a victim of domestic violence, assault or stalking, genetic information, political affiliation or activities, medical or health conditions, marital status	-None		Disclosed: -None Shared or Sold: -None
Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	-Directly from you via our website, telephone, mobile app, in-person [-Direct communication with you -Other individuals -Rewards programs -Social media interaction with you -Marketing agencies -Franchisees -Business partners]	-Provide you with goods and services -Invite participation in surveys and feedback -Customer service communications -Improve promotions [-To provide rewards to loyalty club members]	Disclosed: -Card processor -Vendors -Stored value account administrator -Affiliates Shared or Sold: -None
Internet or Other Electronic Activity	Browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement	-Directly from you via our website [-Direct communication with you -Social media interaction with you -Marketing agencies]	-Provide you with information, goods and services -Invite participation in surveys and feedback -Customer service communications -Improve promotions -To monitor click through rate	Disclosed: -Vendors -Affiliates Shared or Sold: -None
Geolocation Data	Device location	-From your digital device -Direct communication with you	-Provide you with goods and services -Customer service communications -Improve promotions	Disclosed: -Vendors -Affiliates Shared or Sold: -None
Professional or Employment-Related Information	Work history, Industry	-Directly from you by telephone, our websites, our mobile apps, in person  [-Survey data from analytics provider]	-Customer service communications -Improve promotions	Disclosed: -Vendors -Affiliates Shared or Sold: -None
Education Information	Education level	-Directly from you by telephone, our websites, our mobile apps, in person  [-Survey data from analytics provider]	-Customer service communications -Improve promotions	Disclosed: -Vendors -Affiliates Shared or Sold: -None
Inferences Drawn from Other Categories to Create a Profile	Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, knowledge of food preferences	-Directly from you via our website -Direct communication with you -Social media interaction with you [-Survey data from analytics provider -Marketing agencies]	-Provide you with goods and services -Customer service communications -Improve promotions -Understand other data points on Consumers	Disclosed: -Vendors -Affiliates Shared or Sold: -None

1. SENSITIVE PERSONAL INFORMATION WE COLLECT AND DISCLOSE

Category of Sensitive Personal Information	Sources From Which This Sensitive Personal Information is Collected	Business Purposes for Collection	Types of Vendors or Third Parties with Whom This Sensitive Personal Information is Shared, Sold or Disclosed
Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to the individual’s account	-Directly from you via our website	-Complete transactions -Offer services and discounts -Prevent fraud	Disclosed: -Vendors -Stored value account administrator -Affiliates Shared or Sold: -None

We will not collect any category of Personal Information  (including Sensitive Personal Information) that is not listed above or use or Disclose any Personal Information (including Sensitive Personal Information) for a Business Purpose not listed above, without first providing you with notice.

3. RETENTION OF DATA

We intend to retain each category of Personal Information described above only for as long as necessary to fulfill the purpose for which it was collected, or a related and compatible purpose consistent with the average Consumer’s expectations, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain Personal Information: why we collected the Personal Information; the nature of the Personal Information; the sensitivity of the Personal Information; our legal obligations related to the Personal Information, and risks associated with retaining the Personal Information.

4. YOUR RIGHTS TO YOUR PERSONAL INFORMATION

California, Colorado, Virginia, Utah, and Connecticut consumers have certain rights with respect to the collection and use of their Personal Information. Those rights vary by state. As required by the CCPA, we provide detailed information below regarding the data subject rights available to California consumers. Colorado, Virginia, Utah, and Connecticut consumers have similar rights and can find more detail by referencing the CPA, VCDPA, UCPA, or CDPA, as applicable.

You have the right to request certain information regarding the Personal Information we have collected about you. You may make such a request up to twice in a 12- month span. Please note that there are circumstances in which we may not be able to comply with your request, including when we cannot verify your request or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request, if this is the case.

1. RIGHT TO RECEIVE INFORMATION ON PRIVACY PRACTICES

You have the right to receive the following information at or before the point of collection:

• The categories of Personal Information to be collected;
• The purposes for which the categories of Personal Information are collected or used;
• Whether or not that Personal Information is sold or shared with Third Parties or disclosed to Vendors;
• If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or Shared; and
• The length of time the business intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.

We have provided such information in this Supplemental Policy, and you may request further information about our privacy practices by contacting us as at the contact information provided below.

1. RIGHT TO KNOW AND RIGHT TO ACCESS

You have the right to request certain information we have collected about you. You have the right to request:

• Specific pieces and categories of Personal Information we collected about you;
• The categories of sources from which Personal Information was collected;
• The purposes for which Personal Information was collected, Shared, sold, or processed;
• The categories of Personal Information we Shared, sold or Disclosed for a Business Purpose; and
• The categories of Vendors or Third Parties with whom we Shared or sold Personal Information or Disclosed Personal Information for a Business Purpose.

1. RIGHT TO DELETE

You have the right to request that we delete certain Personal Information that we have collected.

1. RIGHT TO CORRECT

You have a right to request that we correct any inaccurate Personal Information we may retain about you.

1. RIGHT TO OPT-OUT OF THE SALE AND SHARING OF YOUR PERSONAL INFORMATION

You have the right to opt-out of the sale and Sharing of your Personal Information with Third Parties, and the right to opt out of the processing of Personal Information for targeted advertising purposes, as defined in the CCPA, CPA, VCDPA, UCPA, and CDPA.

As mentioned above, we do not sell or Share (as defined in Section 1 above) your Personal Information with Third Parties. We also do not have actual knowledge that we sell or Share Personal Information of Consumers under 16 years of age. However, this section allows you to record your preference that we not sell or Share your Personal Information with Third Parties in the future.

If you would like to request that we do not share your Personal Information pursuant to the requirements of the CCPA, click here. The link will take you to an interactive webform that you can complete and submit to make a request to opt-out.

If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that he, she, or it has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.

If you opt-out of the sharing of your Personal Information, we will wait at least 12 months before asking you if we may share your Personal Information. You have the right to opt-in to the sharing of your Personal Information after you have opted out. If you would like to opt-in to the sharing of your Personal Information, please email us at info@culinaryscene.com. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.

Global Privacy Control (“GPC”) is a setting that you can enable in your web browser to communicate your privacy preference for not having certain information about your webpage visits collected across websites. For more details, including a description of how to turn on GPC, visit https://globalprivacycontrol.org/. Our Site recognizes and responds to GPC signals.

1. RIGHT TO LIMIT THE USE OF YOUR SENSITIVE PERSONAL INFORMATION

You have the right to instruct us to limit the use and disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods reasonably expected by an average Consumer or for specific business purposes defined by applicable law. However, we do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA.

1. RIGHT TO NON-DISCRIMINATION

You have a right to exercise the above rights, and we will not discriminate against you for exercising these rights. If you are an employee, job applicant, or independent contractor of Roth Corporation, we will not retaliate against you for exercising your rights under the CCPA. Please note that a legitimate denial of a request to access, delete, or opt-out is not discriminatory, nor is charging a fee for excessive or repetitive requests, as permitted by the CCPA.

1. HOW TO EXERCISE YOUR RIGHTS

If you would like to make any of the data subject requests listed above, please email us at info@culinaryscene.com. When you submit a request to exercise your data subject rights, we may ask you to provide information that will enable us to verify your identity. Please see Section 5 (“Verification Process”) below. The level of verification will depend on the request being submitted. Subject to Section 5 (“Verification Process”) below, you may designate an authorized agent to exercise your data subject rights on your behalf.

1. RIGHT TO APPEAL

You have the right to appeal our decisions about your data subject requests. If you would like to appeal a decision regarding your data subject requests, please email us at info@culinaryscene.com. Please state that your request is an “Appeal,” and describe the date and nature of your original request.

5. VERIFICATION PROCESS

When you submit a request to exercise your data subject rights, we may ask you to provide information that will enable us to verify your identity.

You may designate an authorized agent to exercise your data subject rights on your behalf. If your authorized agent does not have a power of attorney pursuant to state law in your state of residence, then we may require your authorized agent to provide proof that you have given the agent signed permission to submit the request, and we may also require you to either: (i) verify your own identity directly with us, or (ii) directly confirm with us that you have provided the authorized agent permission to submit the request.

We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof. 

6. ADDITIONAL CALIFORNIA PRIVACY RIGHTS

Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information, as defined under California law, during the preceding year for third-party direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the information in writing at:

Roth Corporation

742 S. Broadway

Denver, CO 80209

7. CHANGES TO OUR SUPPLEMENTAL POLICY

This Supplemental Policy is current as of the Effective Date set forth in the Roth Corporation Website Privacy Policy. We may change this Supplemental Policy from time to time in our sole discretion. To let you know when we make changes to this Supplemental Policy, we will amend the Effective Date. The new modified or amended Supplemental Policy will apply from that new Effective Date, so please be sure to check back periodically. Your continued use of the Site after any change to this Supplemental Policy will constitute your acceptance of the changes. Roth will not use your personally identifiable information, in a manner that is materially different than what was stated at the time it was collected, without your consent.    

8. CONTACT US

If you have any questions regarding this Supplemental Policy, or our practices regarding the collection, use, disclosure, sale, sharing, and retention of Personal Information, you may send an email to info@culinaryscene.com or write to:

Roth Corporation
742 S. Broadway
Denver, CO 80209