Privacy policy

Rightly Instructed LLC Privacy Policy

This Privacy Policy ("Privacy Policy") describes the privacy practices applicable to Rightly Instructed LLC ("Rightly Instructed", "we", "us" or "our"), which operates rightlyinstructed.com (the "Site"). This Privacy Policy informs users of the Site about our collection, use, distribution, and protection of personal information collected from users ("user(s)","you" or "your") on the Site ("information" or "user information"). Please read this Privacy Policy carefully before using the Site. This Privacy Policy applies to Rightly Instructed, the Site, and all products and services offered by Rightly Instructed.

What information does Rightly Instructed collect?

Rightly Instructed collects and uses information when a user:

visits a website of Rightly Instructed;
sends an email (for example, sends us a question);
calls us;
purchases a product or service, including a subscription, from Rightly Instructed;
makes a personal account;
logs-in to the Site with credentials from a third-party site, such as Amazon;
participates in a Rightly Instructed contest, sweepstakes, giveaway program, or other promotion;
registers for Rightly Instructed's blog, newsletter, or other communications; and
uses other features of the Site that may be offered from time to time.

In addition, Rightly Instructed collects and uses information about individuals when:

an applicant for employment with Rightly Instructed sends us his or her information;
we engage service providers to provide Rightly Instructed services; and
we engage in sales and marketing efforts, including through third-party vendors.

We may process the following information in connection with these activities:

name;
sex;
company name;
address details;
email address;
telephone number;
date of birth;
gifting, referral, and family relationships;
employment history;
information regarding Site visits, such as the type of browser and operating system, the domain name, the Internet service provider, which pages are visited and for how long, geographic location, and the unique number (such as IP address) assigned to a server or Internet connection; and
information associated with a user's social media or third-party account, if used to log-in to the Site.

Payment information, including credit card information, is processed by third parties and third-party processing applications, such as Shop Pay, PayPal, and Quadpay. We do not have access to the credit card and payment information collected by those third parties and you should review their privacy policies before submitting your information to them.

You may refuse to supply information, but it may prevent you from using certain areas of the Site or engaging in certain interactions with us, such as seeking employment with us.

We may process additional information in the context of fraudulent transactions and/or other legal or regulatory obligations applicable to Rightly Instructed.

By submitting any such information to Rightly Instructed, you agree that Rightly Instructed may collect your personal information and you consent to the collection, use, disclosure, and transfer of such information in accordance with this Privacy Policy and as permitted by applicable law. For information on how to withdraw your consent, see below.

For what purposes does Rightly Instructed process information?

We process information for various purposes, including:

to comply with relevant legal and regulatory requirements;
to be able to deliver and provide our products and services;
to provide relevant information to parents about their child's development;
to process payments;
to create, manage, and administer accounts;
to answer questions and/or comments received from users;
to administer, fulfill, and enforce contractual obligations;
to keep users informed about our products, services, collections, and promotions;
to learn about and analyze users' demographics, interests, behaviors, and relationships for marketing and other purposes;
to promote our products and services, including through online behavioral advertising;
to conduct web analytics, including analyzing usage patterns on the Site;
to manage our business and support business functions;
to evaluate job applicants;
to develop new products and services;
to notify you of product recalls or safety issues;
to engage service providers;
to enter business relationships with third parties; and
to improve the quality and security of the Site.

On what grounds does Rightly Instructed process information?

For data subjects in the European Union and European Economic Area (collectively, "EU"), the United Kingdom ("UK"), and Switzerland, we process information based on the following grounds:

consent, which can be revoked at any time;
the promotion of our legitimate interests;
the preparation and implementation of an agreement; and/or
to comply with a legal obligation.

To which parties does Rightly Instructed share information?

We share information with third parties that we engage to provide services to us. For example, we use third party administrators to operate the business including, but not limited to, sending out communications, shipping, website management, cloud storage, and financial institutions. The parties involved in the above processes may only process information when necessary and pursuant to our instructions. We also share user information with parties that provide us analytic, advertising, and marketing services, as well as additional customer data.

We may share information with our business partners, affiliates, and advertisers.

We may share or transfer information if we enter a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets, or in preparation for any of these events.

We may share with third parties information that has been deidentified or anonymized such that the third party cannot personally identify you from the information we share.

We may disclose information if we believe that the Site is being used to commit unlawful acts; if disclosure of 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; to protect your safety or security, including the safety and security of property that belongs to you; or to protect the safety and security of the Site or third parties.

We may also share your information with other parties based on your consent.

Any information provided to Rightly Instructed may be transferred from Canada, the EU, the UK, or Switzerland to, and stored and processed in, the United States ("U.S."), where Rightly Instructed LLC is headquartered. If you are located outside the U.S., please be advised that by submitting information to Rightly Instructed, you explicitly authorize its transfer to, and storage and processing in, the U.S and that the U.S. does not offer safeguards to protect information that are as stringent as some other jurisdictions in the world. The EU, for example, does not consider U.S. privacy safeguards to be adequate to protect personal information. When we collect information from outside of the U.S., we may rely on various mechanisms to transfer and process that information in the U.S. Such mechanisms include your consent; the establishment, exercise, or defense of legal claims; legal arrangements such as data protection clauses; and the performance of a contract. If we rely solely on your consent, and not another mechanism, you have the right to withdraw your consent by contacting Rightly Instructed customer support.

Text Marketing and notifications:

By entering your phone number in the checkout and initializing a purchase, subscribing via our subscription form or a keyword, you agree that we may send you text notifications (for your order, including abandoned cart reminders) and text marketing offers. Text marketing messages will not exceed 5 a month. You acknowledge that consent is not a condition for any purchase.

If you wish to unsubscribe from receiving text marketing messages and notifications reply with STOP to any mobile message sent from us or use the unsubscribe link we provided you within any of our messages. You understand and agree that alternative methods of opting out, such as using alternative words or requests will not be accounted as a reasonable means of opting out. Message and data rates may apply.
For any questions please text HELP to the number you received the messages from. You can also contact us for more information. If you wish to opt out please follow the procedures above.

Cookies and social media buttons

We use various technologies to collect information about users, including information about their online behavior and devices. Information collected through technology includes usage details, IP addresses, geolocation information, operating systems, browser types, unique device identifiers, and other information about browsing activity, device, and internet connection.

We use technologies to collect information about users' online activities over time and across third-party websites or other online systems. Third-party advertising companies and our service providers may also use cookies and other technologies to collect information about users and their activities on the Site and other websites for a variety of purposes, including providing users with advertisements that may be of interest to them on the Site and third-party sites. This type of advertisement customization is sometimes referred to as "online behavioral" or "interest-based" advertising. The use of tracking technologies by third parties at the Site is subject to those third parties' privacy policies, and not this Privacy Policy. Please see the section below for information about how you can opt out of some forms of interest-based advertising.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

We use Google Analytics to analyze usage of the Sites. You can review how Google uses this information and how you can control information collected by Google Analytics here.

What rights and choices do users have?

Opt-Out of Marketing. You may opt-out of receiving marketing solicitations from us by contacting Rightly Instructed customer support. Even if you opt-out, we may still use and share the information we collect for non-marketing purposes.

Unsubscribe from Emails. Our marketing emails, if any, will include an automated way for you to opt out (unsubscribe) from marketing emails sent by us. To unsubscribe, please follow the instructions in the email you receive.

Interest-Based Advertising. You can obtain information about your choices concerning online behavioral advertising, including how you can opt-out of some uses of information collected by members of the Network Advertising Initiative that may serve advertisements on the Site, by visiting here or, if you are located in the EU, the UK, or Switzerland, please visit here.

You can opt out of interest-based advertising via Facebook and Google through the links below:

Facebook - https://www.facebook.com/settings/?tab=ads
Google - https://www.google.com/settings/ads/anonymous

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

European Union and United Kingdom Data Subjects. If a user is located in the EU, the UK, or Switzerland and the General Data Protection Regulation, UK General Data Protection Regulation, or Swiss Federal Data Protection Act (or any applicable predecessor act) (collectively, "GDPR") applies to our processing of his or her personal information (as defined in the GDPR) as a data controller, he or she has the following rights with regard to the processing of personal information:

Right of access

The user has the right to view the information that we collect from him or her. If a user requests this, we will provide the user with an overview of the information that we process about the user.

Right to rectification

If a user requests this, we will rectify or supplement the user's information.

Right to erasure and the right to be forgotten

The user has the right to request the deletion of his or her information. We are obliged to delete processed user information in the following cases:

- the information is no longer needed for the purposes for which it was originally processed;

- the user withdraws his or her consent and there are no other legal grounds for the processing;

- the user objects to the processing and we have no legitimate interest in processing the user's information;

- the user's information has been processed unlawfully; or

- the user's information must be deleted to comply with a legal obligation.

The right to restriction

The user has the right to temporarily cease the processing of his or her information in the following cases:

- the user disputes the accuracy of his or her information for a period that allows us to verify the accuracy of his or her information;

- the processing is unlawful and the user is against the erasure of his or her information and instead requests the restriction of the processing of his or her information; or

- we no longer need the information for our processing, but the user needs his or her information for the establishment, exercise, or defense of legal claims.

Right to object

The user has the right to object to the processing of his or her information in the following cases:

- the processing is based on our legitimate interests;

- we process the user's information for direct marketing; or

- we process the user's information for scientific research or statistical purposes.

However, we may decline the user's request if we have compelling, legitimate grounds that outweigh his or her interests, or if the processing is for the establishment, exercise, or defense of legal claims.

Right to data portability

A user has the right to obtain the personal information provided by him or her to us in a structured, commonly used, and machine-readable form and to transfer the personal information to another party. On request, we can transfer the personal information for the user, if this is technically possible. The right to data portability can only be exercised when the following two grounds are met:

- the processing is based on the user's consent or on the performance of an agreement; and

- the processing is carried out by automated processes.

A user can submit a request to us to exercise one or more of the above rights. The user must provide contact details with this request, so that we can contact the user in response to his or her request. We reserve the right to ask the user to verify his or her identity, with the level and type of verification depending on the nature of the request and/or the nature of the personal information involved in the request. We will not generally charge fees to handle requests; however, if requests are manifestly unfounded or excessive, we may deny them or charge a fee.

A user can send his or her request to us by e-mail via our Contact Us page. The user must be as clear and precise as possible in the request. The user must, in any case, state which right he or she wishes to exercise and on what grounds.

A user has the right to file a complaint with the local data protection authority at any time if he or she believes that his or her privacy rights are being violated. However, we appreciate it if the user submits the reason for the complaint to us first, so that we can come to a solution together with the user.

The rights listed above have important legal exceptions and limitations. We may deny or exclude certain information in responding to the request, for example, to protect the privacy of other individuals or for legal or other reasons.

Notice to California Residents

If a user is a California resident and the California Consumer Privacy Act of 2018 ("CCPA") applies to our processing of his or her personal information (as defined in the CCPA) as a business under the CCPA, this section provides additional information to such user. This section does not apply to any matters exempted from the CCPA during the period of exemption. If you have a disability and need information on how to access this Privacy Statement in an alternative format, please contact Rightly Instructed customer support.

Categories of Personal Information: We collect the following categories of personal information and may have collected any or all of this information in the preceding 12 months: (a) identifiers such as name, postal address, email address, and account name; (b) categories described in Cal. Civ. Code §1798.80(e), such as telephone number; (c) certain characteristics of protected classifications under California or federal law, such as age over 40 and sex; (d) commercial information, including records of products or services purchased, obtained, or considered; (e) Internet or other electronic network activity information, including browsing history, search history, and information regarding a consumer's interaction with an Internet Web site; and (f) geolocation data. The sources and our use of this personal information is described above in this Privacy Statement.
Disclosure or Sale of Personal Information. We may disclose personal information for business purposes and to the third parties described above in this Privacy Statement. We do not sell personal information to third parties for money. However, the CCPA defines the act of "selling" very broadly, and it may include relationships we have entered into with third parties for marketing, advertising and other purposes related to our business. For example, we may provide information in cookies, pixels, IP addresses, and other identifiers with third parties so we can identify audiences we think would like our products or services and/or show our ads when you visit other websites. The Site may be used only by individuals who are 18 years and older who can form legally binding contracts under applicable law. We do not sell the personal information of any individual less than 16 years of age, including the name and date of birth of a child for whom a user may have purchased products. Users have the right to opt-out of our sharing personal information with third parties (subject to certain exceptions) by following the instructions below. We may still share user information with our service providers.
CCPA Requests. Users have the right to make the following requests to the extent permitted by law.

Right to Know: Users may request that we disclose the following information, applicable to the 12-month period preceding the receipt of the request: (a) categories of the user's personal information we collected; (b) categories of sources of the user's personal information; (c) business or commercial purposes for collecting the user's personal information; (d) categories of third parties with whom we shared the user's personal information; and (e) specific pieces of the user's personal information we collected. We are not required to provide this information to the same person more than twice within a 12-month period.
Request to Delete: Users have the right to request deletion of personal information we collected.
Request to Opt-Out: Users have the right to opt-out of the sale of personal information to third parties.

A user may submit any of the above CCPA requests by contacting Rightly Instructed customer support. These rights have important conditions and exemptions, and we reserve the right to deny or limit the response to these requests to the extent permitted by applicable law. We generally do not charge fees to handle requests.

We reserve the right to ask the user to verify his or her identity, with the level and type of verification depending on the nature of the request and/or the nature of the personal information involved in the request. Users may use an authorized agent to submit a request if the agent has the user's legal power-of-attorney or the user provides the agent signed permission, verifies the user's identity with us, and confirms with us that the user provided the authorized agent permission to submit the request. The authorized agent must contact Rightly Instructed customer support to verify these requirements. We may deny or limit the response to requests where we are unable to verify a user's identity or the authorized agent's authority, or we suspect fraudulent or malicious activity. Users have the right not to receive discriminatory treatment for exercising CCPA privacy rights.

How does Rightly Instructed secure information?

Although we employ technical and organizational controls that we believe are reasonably appropriate to protect personal information, we cannot guarantee that our security precautions will protect against the loss or misuse of information. Similarly, we cannot guarantee the privacy of information you transmit over the Internet or that may be collected in transit by others, including contractors that provide services to us. However, when we ask a third party to process user information on our behalf, we will ensure that the third party has appropriate security measures in place before sharing any information.

How long does Rightly Instructed keep information?

We keep information for as long as necessary for the purposes mentioned in this Privacy Policy, including for the fulfillment of our contractual and legal obligations and for as long as a user accepts marketing communications from us. We may also process and retain information for other purposes, if and/or for as long as the law allows us to retain it for certain purposes. This includes defense against possible legal claims.

Global Application

Our privacy practices are subject to applicable laws, rules, and regulations in the countries and regions in which we operate, which means we engage in the practices described in this Privacy Statement in a particular country or region only as permitted by the laws of such jurisdictions.

Changes to this Privacy Statement

We reserve the right, in our discretion, to supplement, or change this Privacy Policy and implement new or revised privacy policies in particular countries or regions at any time and from time to time. The most recent version of our Privacy Policy can be found on the Site. We therefore recommend that users visit this website regularly to learn more about the information we process. If we materially change the way we process users' information or if we need to notify our users of a change to the information we hold about them, we will contact those users by posting a notice on the Site, emailing such users, and/or through other methods.

By continuing to access or use the Site and our services after changes to this Privacy Policy become effective, you agree to be bound by the terms of the revised Privacy Policy.

Questions

We are of course happy to answer questions from users regarding the processing of their information by Rightly Instructed. Users can contact Rightly Instructed customer support with any questions.

This Privacy Statement was last updated on August 21, 2021.

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