Privacy Policy

Effective Date: Novmber 10th, 2021 

This is the Privacy Policy hosted at https://ruggable.co.uk by Ruggable LLC ("we" "us "  and "Ruggable") headquartered in California, USA.  Please see below for our contact details.

At Ruggable, we take your privacy seriously. Please read the following to learn how we treat your personal information. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect directly from users of our website, located at https://ruggable.co.uk, users who engage with our other online content (e.g. on social media) and recipients of our emails, including use of any of our services through a mobile device or otherwise (the “Services”).

Remember that your use of Ruggable’s Services is at all times subject to our Terms of Service which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our website at ruggable.com (or local equivalents) (the "Site") or otherwise interact with our Services. “Personal Data” means any information that identifies or relates to a particular individual or from which an individual may be indirectly identified (e.g. from pieces of information in combination with each other).

Personal Data We Collect and How We Use It

Depending on how you interact with our Services (through the Site, social media, online adverts, etc.), we collect different categories of Personal Data and use them in different ways, as we set out below:

1. Information you provide to us when you interact with us

• Account information: such as your name, customer number, login ID, username, password, and/or security question and answer, and other registration information. Certain login information, such as your customer number, may be generated by us and then sent to you. We only collect (or create for you) unique login information for those activities that require an account. Your unique login information, especially your password, should always be kept confidential and should never be shared with anyone else.

• Personal contact information: This includes your name, home or postal address, phone number and email address. This could include information that you give us about someone else (for example, if you ask us to ship a product to someone else).   We collect personal contact information in connection with account registration, product orders, customer service, registration to receive offers, discounts and marketing updates and customer feedback.

• Order and product information: This includes details of the products you have ordered and searched for on our Site, and the time, date of orders and searches. We use this information to send you (with your consent) promotional emails for products and offers tailored to your interests, to make personalised recommendations of products when you return to the Site, to advertise to you when you visit social media platforms like Facebook or other websites and to better understand our customers so we can improve our products and our users' experience of our Site.

• Demographic information and preferences: This includes any information that describes demographic characteristics and preferences, such as age, gender, preferences, interests, date of birth, age or age range, general geographic location (e.g., post code or city and state), favorite products, or lifestyle information.   We use this information to send you promotional emails and communications to make personalised recommendations of products when you return to the Site, to advertise to you when you visit social media platforms like Facebook or other websites and to better understand our customers so we can improve our products and our customer's experience of our business both offline and online.  We may also use this information to make our business more responsive to the interests of like-minded consumers. For example, we may use this information to help deliver our ads to you on social media platforms, such as Facebook. We work with social media platforms like Facebook to create “ “Lookalike Audiences” (where targeted ads are sent to people on social media platforms like Facebook who have similar characteristics, determined by us and / or Facebook, to our customers and website visitors). Lookalike Audiences may also include current customers and website visitors, if they also display those same characteristics identified by us and / or Facebook. See “Online advertising” below for more detail about how we work with social media platforms.

• Your feedback: Examples include comments and suggestions, testimonials, or other feedback you send us about what you may have liked (or disliked) about your experience in using our products or services. We typically collect this information in the form of customer surveys, for example, post purchase pop-up questionnaires, feedback forms, and email correspondence. We use your feedback to understand what our customers think of our products and the experience they have of us, to improve our products and the customer experience and – if you agree to - to discuss your feedback with you. We may also use the information we learn from your purchase to help improve our products, develop new products, or inform our marketing campaigns. Often, we collect feedback separately from your order, for example, through a pop-up window on our Site, and we may be able to associate your feedback with your personal and order information. We may use cookies and other similar technologies when we gather your feedback. Please see our Cookie Statement for further information.  

• User-generated content and posts:  Any content that you create and then share with us (and perhaps others) by uploading it to one of our websites or applications, such as our Facebook fan nonpages or applications. Examples include photos, videos, personal stories, or other similar media or content.

• Payment and Transaction-related information: This includes any information that you use to make a purchase, such as your payment card details, gift card information, other forms of payment we make available. We only collect payment information for purchases. If you create an account with us, your payment information (along with your purchase history and other related preferences) may be stored under your account profile. We use this information to process your payments when you order products from us, to enable you to redeem or to give gift vouchers and to record your payment information for faster checkout if you choose to do that. Where we allow you to buy products from the Site, payments made on the Site are made through our payment gateway provider. You will be providing credit or debit card information directly to them, encrypting your credit/debit card information and authorising payment. 

2. Automatically collected information

When you use the Site, we use various technologies (including cookies and pixel tags) to collect certain information about how you use the Site. We use this information to understand your preferences better so we can improve, deliver our advertising on social media and other sites and for security and anti-fraud purposes.

Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content, and enable you to use your social media accounts in conjunction with the Site and enable us to advertise to you on our Site, social media platforms (like Facebook) and other sites and apps.   For more details, see our Cookie Statement.

3. Online advertising

We work with social media platforms and digital advertising platforms to:

• Show you advertising for our products on other websites and social media platforms. For instance, if you show an interest or buy a product on our Site, we may advertise that or other products we think may be of interest and you may see them on other websites and on your Facebook or other social media feeds. To do this we will share information with our social medial and digital advertising partners about you, your purchase, age, gender and interests for instance so they can better understand what you are interested in and so we can deliver ads to you which we think might be of interest. For example, we work with social media platforms, such as Facebook, to create “Custom Audiences”, where targeted ads are sent to people on Facebook who have already been on our Site. "Custom Audiences" are created by matching data we collect with the data third parties have. For example, we may share locally hashed customer and Site visitor information and transmit the resulting hashed data to third parties, or we may incorporate a third party pixel onto our site, or otherwise share information with third parties, from these data sets third parties are able to identify common data. We also work with social media companies, like Facebook, as described above, to deliver our ads to a "Lookalike Audience".  Facebook's settings allowing you control over how the platform uses your data, and further detail on Facebook's use of data in advertising, are available here: https://www.facebook.com/help/109378269482053/?helpref=hc_fnav and Facebook's privacy policy is available here: https://www.facebook.com/about/privacy/.  For more information about how to turn this feature off see below or visit http://www.youronlinechoices.eu or your social media privacy settings. 

Our social media and digital advertising partners also use cookies and similar technologies to deliver our adverts, so please see our Cookie Statement.

4. Klarna

In order to be able to offer you Klarna’s payment options, we will collect and share with Klarna certain aspects of your personal information, such as personal contact information, order and product information, and Klarna may collect information directly from you, for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you. Your personal data is processed by Klarna in accordance with the information in Klarna’s privacy policy. You can find general information on Klarna here.

5. Other uses

We use all of the information described above for the following general purposes:

• To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.
• To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Service.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive marketing communications from us, please indicate your preference by emailing us at support@ruggable.co.uk.

How Personal Data May Be Disclosed

1. Your Personal Data (as listed above in Personal Data We Collect and How We Use It) may be disclosed with the following categories of third parties:

• to our third-party service providers who provide services such as website hosting, data analysis, payment processing, product delivery, fraud detection, advertising providers and partners, email delivery services, customer relationship management, survey and feedback collection services, credit card processing, staff augmentation and contract personnel, auditing services and other services, to enable them to provide services and for purposes described in this Privacy Policy. Certain of these vendors process Personal Data on our behalf in the United States and other countries outside the European Economic Area.   For example, we work closely with Shopify to deliver this Site and provide our products to you. For some categories of data, Shopify also handles your data for their own limited purposes such as for risk and fraud screening and related uses. For information about how Shopify handles your Personal Data visit https://www.shopify.com/legal/privacy.
• to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.
• If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to establish, exercise, defend, enforce or apply our terms of service or sale and other agreements or legal claims; investigate or prevent actual or suspected unlawful activity, loss or harm and to protect the rights, property, or safety of our customers, or others; or as otherwise required or permitted by law.  This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
• to other companies in the Ruggable group from time to time and for purposes set out in this Privacy Policy.

2. Your name and contact information (and other information you make public) may be disclosed with the following categories of third parties:

• to third-party strategic partners with whom we may enter into a special relationship for promotional activities, where permitted by law.
• to third parties in connection with certain promotions or sweepstakes you may participate in; to the extent that the promotion’s rules concerning the treatment of your Personal Data are stricter than this Privacy Policy, the promotion’s rules apply.

3. Information that is automatically collected when you use the Site may be disclosed with the following categories of third parties:

• our online and email advertisers, social media partners or other third-party vendors we use who may provide Cookies or other similar technologies for use on our Site to manage and improve our online and email advertising campaigns.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, the Site uses industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account.

We retain Personal Data about you for as long as necessary to provide you with our Services. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data from children under 18; if you are a child under 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us Personal Data, please contact us at support@ruggable.co.uk.

Data Subject Rights

Lawful basis under GDPR

We will only process your Personal Data if we have a lawful basis under the GDPR for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We process Personal Data in the form of your name, address(es), order details, email address and phone number in order to comply with our contractual obligations to deliver products to you or to take steps at your request prior to an order being finalised.  When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of our Site that require such data, for instance the ability to order products.
• Legitimate Interests: This is a technical term in data protection law which really means we have a good and fair reason to use your data and we do so in ways which does not hurt your interests and rights.  We use your data in our legitimate interests where it is reasonably expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will send you promotional communications about our service, subject to your legal rights to control this. We also analyse how users interact with our Site so we can understand how different elements of the Site are working so we can improve and develop the Site.  We also process your data to guard against fraud and security threats and may do so in the completion of corporate transactions for the sale or part or all of our business.
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data.  When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Compliance with law: for instance, we keep Personal Data in the form of order and transaction records to comply with our tax record obligations under legislation.
• Other Processing Grounds: From time to time we may also need to process Personal Data if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below.  For more information about these rights, or to submit a request, please:

• Email us at: privacy@ruggable.com
• Submit a form at this address: preferences.ruggable.com/privacy

Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision.  In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. 

• Access:  You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
• Erasure: You can request that we erase some or all of your Personal Data from our systems. 
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability:  You can ask for a copy of your Personal Data in a machine-readable format.  You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing:  You can ask us to restrict further processing of your Personal Data.

Right to File Complaint:  You have the right to lodge a complaint about Ruggable’s practices with respect to your Personal Data with the supervisory authority in the UK, the Information Commissioner's Office.

Transfers of Personal Data

The Site is hosted and operated in the United States (“U.S.”) through Ruggable and its service providers, and the laws in the U.S. may differ from the laws in the UK. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Ruggable in the U.S. and will be hosted on U.S. servers and processed in the U.S. and you acknowledge that Ruggable will store and process your information to and in the U.S., and possibly other countries. Ruggable we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism including standard contractual clauses, and that it is treated securely and in accordance with this privacy policy.

Examples of when we may transfer your personal information outside the EEA include:

• In order to store it.
• In order to enable us to provide goods or services to you and fulfil our contract with you. This includes displaying our products to you, in order fulfilment and the provision of customer support services.
• Where we are legally required to do so.
• In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. Those changes will go into effect on the Effective Date shown in the revised Privacy Policy. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, please do not hesitate to us at contact us at privacy@ruggable.com.