PRIVACY POLICY

This Privacy Policy applies to information collected by AllerRow, and its subsidiaries (“Ref,” “we,” “our” or “us”) in connection with the products and services that Ref offers offline and online.  This includes information collected online through our websites, branded pages on third party platforms (i.e, social networking services), mobile applications, and through our direct marketing campaigns or other online communications, as well as offline through our Customer Love Team, events, in-store campaigns, purchases, and requests, and mobile messaging services (collectively, “Ref Services”).

This Privacy Policy explains what information may be collected through the Ref Services, how such information may be used and/or shared with others, how we safeguard it and how you may access and control its use in connection with our marketing communications and business activities. By using the RefServices, you agree to the collection, use, and disclosure of your information as described in this PrivacyPolicy.  If you do not, please do not use the Ref Services.

This Privacy Policy is hereby incorporated into and forms part of the terms and conditions of use of theRef Services.

Important information

Purpose of this privacy policy

This privacy notice aims to give you information on how Ref collects and processes your personal data through your use of Ref Services.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

​Controller

​We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

​Your duty to inform us of changes

​It is important that the personal data we hold about you is accurate and current.

Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Information collection

Information you provide to us

​When you use Ref Services, we may ask you to provide certain personal information to obtain our products or use our services.  For example, we may ask for information when you register to create an account, update your information, shop in our stores, use certain features, access, upload or download content, purchase products or services, enter into sweepstakes or other promotions, register or participate in a competition, fill out a survey, request customer support, or otherwise communicate with us.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data, which we have grouped together as follows:

Identity Data: first name, last name, username or similar identifier, title, and gender.

Contact Data: email address and telephone number.

Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other details about the devices you use to access Ref Services

Profile Data: your username and password, your interests, preferences and feedback.

Usage Data: information about how you use our website, products and services.

Marketing and Communications Data: your preferences in receiving marketing from us and our third parties.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

Information You Provide When You Participate in an Online Survey or Other Research.
We may also collect information you provide us in connection with participating in an online survey or as a research panel participant.  This may include, but may not be limited to, information about your shopping habits, lifestyle preferences, interests and hobbies, health, physical or behavioural characteristics, or other demographic information, as well as photos, videos, and other user-generated content.

Information You Provide When You Make a Purchase.
If you make a purchase from us, you will be required to provide a credit/debit card number and related financial information (such as CVV, expiration date, and billing address), or other payment information (such as a PayPal or Apple Pay account), depending on the form of payment you choose.

Information You Provide about a Third Party.
You may decide to provide us with another person's information (such as name, email, address, or phone number) so that we may recommend or send products or services to such a person, or so that we may facilitate your communication with other people. Local law may require you to seek the consent of your contacts to provide their personal information to Ref (or in connection with using Ref Services), and we may in turn use that information in accordance with the terms of this Privacy Policy. Where required by law, we will obtain the required consent from the person whose information you provided to us.

Information You Provide Through Social Media.
You may also be given the option to link to your Facebook or other social media accounts through Ref Services. When you do, we may automatically receive certain information from you based upon your privacy settings on those sites. This may include, but may not be limited to, name, user name, demographic information, updated address or contact information, location, interests, and publicly-observed data, such as from social media and online activity.

If you fail to provide personal data. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel the contract you have with us and notify you accordingly.

Information collected automatically

​Whenever you visit or interact with Ref Services, Ref stores, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about your online activity.

​This information may be collected in the following ways

Usage Information: We may use cookies, web beacons, pixel tags, mobile analytics software, log files, or other technologies to collect certain information about your online activity, and interactions with our emails, online and mobile advertisements, and to allow us to keep track of analytics and certain statistical information which enables Ref to improve Ref Services and provide you with more relevant content and advertising offered by Ref, or through or linked from Ref Services.

For example, we may automatically or passively collect certain non-personal information from you, including your browser type, mobile device manufacturer, mobile carrier, phone number, operating system, activations, content, products or services you purchase or access, the page served and the preceding page views or websites visited, any mobile device activity and configurations, and email client. We may also automatically collect information about your use of Ref Services, including the date and time you visit Ref Services, use or click through to any of Ref Services, the areas or pages of Ref Services that you visit, the amount of time you spend viewing or using Ref Services, the number of times you return to Ref Services, other click-stream or site usage data, emails that you open, forward or click-through to our Ref Services, and other sites that you may visit.

​Device Information: We may automatically collect your IP address or other unique identifier (“Device Identifier”) for the computer, mobile device, tablet or other device (collectively, “Device”) you use to access Ref Services, including the hardware model and mobile network information. We may use a Device Identifier to, among other things, provide Ref Services, help diagnose problems with our servers, analyze trends, track users’ web page, email and mobile application movements/activities, help identify or gather broad demographic information for aggregate use, and retarget online and mobile advertisements to you across computers or devices you may use.

Geolocation Information: We may collect information about the location of your Device when you access or use Ref Services. In addition, if you choose to turn on your Bluetooth, Wi-Fi or other geolocation functionality when you use our mobile applications, we may collect and use your geolocation information.

Third Party Service Providers: We may use third party service providers to support Ref Services.  Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files, or other technologies to receive, collect, and store information on our behalf.

Third Party Analytic Technologies: We may use third parties’ analytics and tracking tools, such as Google Analytics, Adobe Marketing Cloud, Facebook Custom Audience and others, to help us track, segment and analyze usage of Ref Services, and to help us or those third parties serve more targeted advertising to you on Ref Services and across the Internet. These tools may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to collect and store non- personal information. They may also combine information they collect from your interaction with Ref Services with the information they collect from other sources. We do not have access to, or control over, these third parties’ use of cookies or other tracking technologies. To learn more about your advertising choices relating to the collection and use of your information, please see the Opt-Out section below.​

We may obtain information about you from other trusted third-party sources to update or supplement the information that you provide or that we collect automatically. This includes, for example, information from public databases or data aggregators that may include your demographic information, media consumption, previous purchases, shopping habits, loyalty program information or lifestyle preferences. We may also receive information about you from our partners and service providers, (including, for example, business partners, analytics vendors, advertising networks and search information providers).

We may use this information to help us maintain the accuracy of the information we collect, personalize your experience with Ref Services, target our communications so that we can inform you of products and services or other offers that may be of interest to you, to measure ad quality and responses, and for internal business analysis or other business purposes.

Combination of information​

We may combine the information we receive from you and about you, including information you provide to us and information we automatically collect through Ref Services, as well as information collected across other computers or devices that you may use, from other online or offline sources, and from third party sources.  This combined information may be used in any manner detailed in this Privacy Policy.

Legal basis for using your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to process your order for it to be shipped to you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

​Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Legal basis for using your personal data

We may use the information about you for a variety of business purposes, including for example:

​For Customer Service and Transactional Purposes, such as to:

  • ​Respond to your questions or requests and provide customer service;
  • Manage your account and registration;
  • Provide you with access to certain features of Ref Services;
  • Validate, confirm, verify, deliver, and track your order (including to arrange for shipping, handle returns and refunds, and contact you about your orders, including by telephone), and send you related information, coupons, products or samples;
  • Verify your identity or communicate with you about your activities with respect to Ref Services;
  • To use and disclose your credit, debit or payment card or other financial information only to process payments and prevent fraud;
  • Contact you with regard to your use of Ref Services and, in our discretion, changes to any Ref policy;
  • Develop new products or services and to enhance current products and services;
  • Protect the security or integrity of Ref Services and our business, such as by protecting against and preventing fraud, unauthorized transactions, claims and other liabilities, and managing risk exposure, including by identifying potential hackers and other unauthorized users; and
  • For other purposes as disclosed at the time you provide your personal information or otherwise with your consent.

We (or our service providers or business partners) may collect information that relates to you, including personal information, such as your name, e-mail address, telephone number, phone number, mailing address, date of birth, gender, and demographic information.

Information You Provide When You Participate in an Online Survey or Other Research. We may also collect information you provide us in connection with participating in an online survey or as a research panel participant.  This may include, but may not be limited to, information about your shopping habits, lifestyle preferences, interests and hobbies, health, physical or behavioural characteristics, or other demographic information, as well as photos, videos, and other user-generated content.

Information You Provide When You Make a Purchase. If you make a purchase from us, you will be required to provide a credit/debit card number and related financial information (such as CVV, expiration date, and billing address), or other payment information (such as via PayPal or Apple Pay), depending on the form of payment you choose.

Information You Provide about a Third Party. You may decide to provide us with another person's information (such as name, email, address, or phone number) so that we may recommend or send products or services to such person, or so that we may facilitate your communication with other people.Local law may require you to seek the consent of your contacts to provide their personal information toRef (or in connection with using the Ref Services), which may in turn use that information in accordance with the terms of this Privacy Policy. Where required by law, we will obtain the required consent from the person whose information you provided to us.

Information You Provide Through Social Media. You may also be given the option to link to yourFacebook or other social media accounts through the Ref Services. When you do, we may automatically receive certain information from you based upon your privacy settings on those sites. This may include, but may not be limited to, name, user name, demographic information, updated address or contact information, location, interests, and publicly-observed data, such as from social media and online activity.

Sharing of information

We may use the information about you for a variety of business purposes, including for example:

​For Customer Service and Transactional Purposes, such as to:

  • ​Respond to your questions or requests and provide customer service;
  • Manage your account and registration;
  • Troubleshoot issues, bugs or defects related to your account or activities;
  • Provide you with access to certain features of the Ref Services;
  • Validate, confirm, verify, deliver, and track your order (including to arrange for shipping, handle returns and refunds, and contact you about your orders, including by telephone), and send you related information, coupons, products or samples;
  • Verify your identity or communicate with you about your activities with respect to the RefServices;
  • To use and disclose your credit, debit or payment card or other financial information only to process payments and prevent fraud;
  • Contact you with regard to your use of the Ref Services and, in our discretion, changes to anyLYMI policy;
  • Develop new products or services and to enhance current products and services;
  • Protect the security or integrity of the Ref Services and our business, such as by protecting against and preventing fraud, unauthorized transactions, claims and other liabilities, and managing risk exposure, including by identifying potential hackers and other unauthorized users;and
  • For other purposes as disclosed at the time you provide your personal information or otherwise with your consent.
  • For Advertising Customization and Analytics Purposes, such as to:
  • Perform market research, understand the effectiveness of our competition or promotions and Ref Services analytics and operations;
  • Personalize and improve Ref Services and our products, services, offers and advertising made available on or outside Ref Services (including on other sites/ applications that you visit).  For example, we may provide personalized or localized content, recommendations, features, and provide content or features that match your interests and preferences;
  • Provide you with customized content, advertisements, offers and promotions offered by Ref or on behalf of our partners and affiliates, and provide news and other information we think will be of interest to you on Ref Services, in emails and across third-party websites;
  • Link or combine with information we receive from others to help understand your needs, use for interest-based or targeted advertising or retargeting on your computers or other devices, and to provide you with better service; and
  • Communicate with you, either directly or through one of our partners (e.g., through Facebook Custom Audience, Google Customer Match, Twitter Match, etc.) for Ref marketing and promotional purposes via emails, notifications, or other messages, consistent with any permissions you may have communicated to us.

Sharing of information

​The information collected or generated through your use of Ref Services may be shared by you or by us as described below.

Sharing of information by you:

Ref Services offer many ways to find, enjoy, and share content.

​Your activity in connection with Ref Services, such as filling out surveys, reviewing and rating products, inquiring about or purchasing products, participation in online communities, “liking” or “sharing” Ref content to your social media accounts or pages or otherwise interacting with Ref Services, may be visible to other users of Ref Services and in some cases, publicly available.

Sharing information by us

​We may share the information collected from or about you in the following ways:

​With Our Affiliates: We may share your information with our subsidiaries and affiliated companies for internal reasons, primarily for business and operational purposes.

​Third Party Service Providers: We may share your information with third party service providers that provide business, professional or technical support functions on our behalf. This includes, but may not be limited to, service providers that host or operate Ref Services; payment processors; analyze data; provide customer service; postal or delivery services, and sponsors or other third parties that participate in or administer any promotions.

​Other Third Parties: Your information may also be shared with our sponsors, partners, advertisers, advertising networks, advertising servers, and analytics companies or other third parties in connection with marketing, promotional, and other offers, as well as product information. Your information may also be shared with third parties we identify at the time you provide your personal information or otherwise with your consent.

​Sweepstakes, Contests, and Promotions: If you choose to enter into one of our sweepstakes, contests, or other promotions (a “Promotion”) we may disclose your information to third parties or the public in connection with the administration of such Promotion, as required by law, as otherwise permitted by the Promotion’s official rules, or otherwise in accordance with the terms of this Privacy Policy.

​Business Transfers: In the event that another entity acquires us or all or substantially all of our assets, or assets related to Ref Services, your information may be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties. Finally, information described in this paragraph may also be disclosed for due diligence purposes in connection with any proposed transaction of the sorts described in this paragraph.

Legal Disclosures; Safety: Ref may transfer and disclose your information to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Service or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, users of Ref Services, Ref, or the public.

Aggregate or Anonymous Non-Personal Information: We may also share aggregate or anonymous non- personal information with third parties for their marketing or analytics uses.

Opting out

Certain parts of Ref Services require cookies. You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features through Ref Services or take full advantage of all of our offerings. Please refer to your Web browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences. On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.

​Our system may not respond to Do Not Track requests or headers from some or all browsers. We may use cookies or other technologies to deliver more relevant advertising and to link data collected across other computers or devices that you may use.

​We, or other parties we do business with, may place or recognize unique cookies or other technologies on your browser when you visit Ref Services to collect information about your use of Ref Services and your other online activities over time and across different websites and apps, and may use that information to serve interest-based advertisements to you as you browse the Internet. To learn more about such interest-based advertising, and to opt-out of such collection and use for online behavioral advertising by the Digital Advertising

Alliance (DAA) participating companies in the United States, please visit: www.aboutads.info/choices/; DAA AppChoices –www.aboutads.info/appchoices.  To opt-out from the use of information about your online activities for online behavioral advertising by NAI member companies, visit: www.networkadvertising.org/choices. Please note that even if you opt- out, you may still receive advertisements from Ref that are not customized based on your Usage Information.

To learn how to manage privacy and storage settings for Flash cookies, please visit www.adobe.com/support/documentation/en/flashplayer/help/settings_manager.html.​

Further Information and opt-out options for some common cookie providers used by us can be found here:
Google Analytics
Google AdWords
Facebook
Twitter

Access and Updates to Your Information. If you wish to verify, correct, or update any of your personal information, you may visit your Account Page or contact us.

Unsubscribing from Communications by Us. We provide our customers with the opportunity to update their information or opt-out of having their information used for purposes not directly related to placement, processing, fulfilment, or delivery of a product order or servicing of your product. To opt-out of marketing communications, you may:​

Send us an e-mail at hey@b-nary.com, or unsubscribe from our marketing email communications at any time by unsubscribing or following the instructions contained within the email.

Data retention

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

​Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a 'Data Subject Access Request'). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.​

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

​Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

​Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Children's privacy

Protecting children’s privacy is important to us. We do not direct Ref Services to, nor do we knowingly collect any personal information from, children under the age of 13. If Ref learns that a child under the age of thirteen has provided personally identifiable information through Ref Services, we will use reasonable efforts to remove such information from our files.

Security of information

We use certain reasonable security measures to help protect your personal information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure.  Please note that we cannot ensure or warrant the security of any information you transmit to us. You use Ref Services and provide us with your information at your own risk.  If we share information with a third party, as detailed in this privacy policy, we shall use all reasonable efforts to ensure that they keep the information secure and only use the information consistent with the terms of this Privacy Policy.

Other sites

Ref Services may contain links to other sites that we do not own or operate. This includes links from service providers, fulfilment companies, advertisers, sponsors, or other business partners that may use our logo(s) as part of a co-branding agreement. We are not responsible for these sites or their content, products, services or privacy policies or practices. These other web sites may send their own cookies to your Device, they may independently collect data or solicit personal information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of Ref Services (including those linked to through an email or social networking page).

Changes

Any changes we may make to our Privacy Policy will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy. If you do not agree or consent to these updates or changes, do not continue to use Ref Services. If we make a material change to this Privacy Policy, we will provide appropriate notice to you.​

In addition to this Privacy Policy, there may be specific campaigns or promotions which will be governed by additional privacy terms or policies. We encourage you to read these additional terms or policies before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or policies will be made prominently available to you.

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