PRIVACY POLICY

RoamingCabbage

Version Date: 7/21/2015

GENERAL

Roaming Cabbage, LLC(“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”) whether they use our website located at www.RoamingCabbage.com, including other media forms, media channels, mobile website or mobile applications related or connected thereto (collectively, “RoamingCabbage”) to market, buy and sell goods and services or simply to view RoamingCabbage. The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of RoamingCabbage, about the types of information that Company may gather about or collect from you in connection with your use of RoamingCabbage. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use RoamingCabbage, however, the current version of this Privacy Policy will apply. Accordingly, each time you use RoamingCabbage you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used RoamingCabbage.  

RoamingCabbage is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing RoamingCabbage from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using RoamingCabbage, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of RoamingCabbage and your agreements with us. Any persons accessing RoamingCabbage from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure different from those of the jurisdictions mentioned above may only use RoamingCabbage in a manner lawful in their jurisdiction. If your use of RoamingCabbage would be unlawful in your jurisdiction, please do not use RoamingCabbage.

BY USING OR ACCESSING ROAMINGCABBAGE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

CHILDREN

The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. Any person who provides personal information through RoamingCabbage represents to us that he or she is 13 years of age or older. If we learn that personal information has been collected from a user under 13 years of age on or through RoamingCabbage, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of RoamingCabbage or has otherwise transferred personal information to RoamingCabbage, please contact Company using our contact information below to have that child's account terminated and information deleted.

GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

Users Generally

“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, Company gathers from users of RoamingCabbage Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system and browser type, and the locations of the Web pages the user views right before arriving at, while navigating and immediately after leaving RoamingCabbage. Company analyzes Non-Personally-Identifying Information gathered from users of RoamingCabbage to help Company better understand how RoamingCabbage is being used. By identifying patterns and trends in usage, Company is able to better design RoamingCabbage to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from RoamingCabbage users in the aggregate, such as by publishing a report on trends in the usage of RoamingCabbage.

Web Cookies

A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the site. We use cookies on RoamingCabbage to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into RoamingCabbage, and to facilitate purchase procedures. Company also uses Web Cookies to track the pages that users visit during each RoamingCabbage session, both to help Company improve users’ experiences and to help Company understand how RoamingCabbage is being used. As with other Non-Personally-Identifying Information gathered from users of RoamingCabbage, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners and others better understand how RoamingCabbage is being used. Company does not attempt to link information gathered using Web Cookies to Personally-Identifying Information. USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING ROAMINGCABBAGE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF ROAMINGCABBAGE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. ROAMINGCABBAGE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Third Party Advertisers

We use third-party advertising companies to serve ads when you visit RoamingCabbage. These companies may use information (not including any Personally-Identifying Information) about your visits to this and other websites that are contained in Web Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the Network Advertising Initiative, you can opt out of several third party ad servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the following link: http://networkadvertising.org/managing/opt_out.asp. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to serve ads.

We allow advertisers to choose the characteristics of users who will see their advertisements and we may use any of the non-personally identifiable attributes we have collected (including information you may have decided not to show to other users, such as your birth year or other sensitive personal information or preferences) to select the appropriate audience for those advertisements. We do not identify you to the advertiser.

Web Beacons

A “Web Beacon” is an object that is embedded in a web page that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on RoamingCabbage and in emails to count users who have visited particular pages, viewed emails, and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information; they are a technique Company may use to compile aggregated statistics about RoamingCabbage usage. Web Beacons collect only a limited set of information including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons, however, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered and permit you to accept or decline Web Cookies on an individual basis.  

Aggregated and Non-Personally-Identifying Information

We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on RoamingCabbage and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to RoamingCabbage and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.

Mobile Device Additional Terms

• Mobile Device. If you use a mobile device to access RoamingCabbage or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system and version information, and IP address.
• Geo-Location Information. Unless we have received your prior consent, we do not access or track any precise location-based information from your mobile device at any time while downloading or using our mobile applications or our services.
• Push Notifications. We send you push notifications if you choose to receive them letting you know when someone has sent you a message, or for other service-related matters. If you wish to opt-out from receiving these types of communications you may turn them off at the device level.
• Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally-Identifiable Information you submit within the mobile application.

COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION

Registration

As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Company collects a range of Personally-Identifying Information from and about RoamingCabbage users. Much of the Personally-Identifying Information collected by Company about users is information provided by users themselves at the time they register to open an account. That information may include each user’s name, address, email address, and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic information, and other relevant information as determined by Company from time to time. Users of RoamingCabbage are under no obligation to provide Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain RoamingCabbage features.

BY REGISTERING WITH OR USING ROAMINGCABBAGE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.

Online Postings

Certain Personally-Identifying Information collected from users is disclosed as a matter of course as a result of those users’ use of RoamingCabbage. We provide areas on RoamingCabbage where you can post reviews and other information relating to your activities on RoamingCabbage. Such postings are governed by our Terms of Use. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION.

Company Communications

We may occasionally use your name and email address to send you notifications regarding new services offered by RoamingCabbage that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account even if you opt out of all voluntary email notifications.

Company Disclosures

Company will disclose Personally-Identifying Information under the following circumstances:

• By Law or to Protect Rights. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our Company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
• Marketing Communications. Unless users opt-out from receiving Company marketing materials upon registration, Company will email users about products and services that Company believes may be of interest to them. If a user wishes to opt-out of receiving marketing materials from Company, user may do so by following the unsubscribe link in email communications,  by going to your account settings or contacting us using the contact information below.
• Disclosure to Trusted Third Parties at Your Request. When visiting RoamingCabbage, we may provide you with advertisements, promotions, sweepstakes and offers from third party providers. If you choose to accept any such offers, you may either (depending on the situation) directly provide your information in connection with the offer to such third party provider, or we will provide your information, including billing information, to the third party provider by pre-populating the offer registration forms. Your information will not be transferred until you actually accept the offer. You may opt-out of the offer at any time up until this point. Please refer to the third party provider’s own privacy policy (provided on the offer pages) if you have any questions regarding how your information is used by such providers. Please be aware that these offers may be presented on pages framed by a Company website. We do this to provide a seamless experience. Although these offer pages have the look and feel of our websites, you will be submitting your information directly to the third-party advertiser. You agree that we will not be responsible or liable for any loss or damage of any sort incurred as the result of any such dealings, including the sharing of the information you supply to us with third party providers described here, or as the result of the presence of such providers on an eHarmony site.
• Business Partners: When you make purchases or engage in promotions offered through RoamingCabbage or our services, we may share Personally-Identifying Information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant's offer or program, you authorize us to provide your email address and other information to that merchant.

• Affiliates. We may share some or all of your personal information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates would include a parent company or any subsidiaries, joint venture partners, or other companies that we control or that is under common control with us. Such intercompany transfers may be to and from the United States and any other country in which we or our agents maintain facilities for the purposes identified in this Privacy Policy, as well as for storage, processing or other business use as permitted under this Privacy Policy. By accessing or using RoamingCabbage you consent to the transfer of your personal information among these entities, including those located outside of your country of residence.

• Third Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting contests, sweepstakes, surveys and other features offered through RoamingCabbage. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.

• Business Transfers; Bankruptcy. Company reserves the right to transfer all Personally-Identifying Information in its possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of Company’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally-Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.

Changing Personally-Identifying Information; Account Termination

You may at any time review or change your Personally-Identifying Information by going to your account settings (if applicable) or contacting us using the contact information below.  Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law. To make this request, either go to your account settings (if applicable) or contact us as provided below. We will retain in our files some personal information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your personal information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account.

General Use

We use the Personally-Identifiable Information in the file we maintain about you, and other information we obtain from your current and past activities on RoamingCabbage to: deliver the products and services that you have requested, manage your account and provide you with customer support, communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties, develop and display content and advertising tailored to your interests on RoamingCabbage and other sites, resolve disputes, troubleshoot problems, measure consumer interest in our services, inform you of updates, customize your experience, detect and protect us against error, fraud and other criminal activity, enforce our Terms of Use, and as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifiable Information to identify users using multiple user IDs or aliases. We may compare and review your Personally-Identifiable Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on RoamingCabbage, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

CONTESTS, GIVEAWAYS AND SURVEYS

From time to time, Company may offer RoamingCabbage users the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy. From time to time, Company may also ask RoamingCabbage users to participate in surveys designed to help Company improve RoamingCabbage. Any Personally-Identifying Information provided to Company in connection with any survey will be used only in relation to that survey, and will be disclosed to third parties not bound by this Privacy Policy only in non-personally-identifying, aggregated form.

COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY

Company contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing Personally-Identifying Information received from Company, other than in accordance with this Privacy Policy. Third parties are under no obligation to comply with this Privacy Policy, however, with respect to Personally-Identifying Information that users provide directly to those third parties or that those third parties collect for themselves. These third parties include advertisers, providers of games, utilities, widgets and a variety of other third party applications accessible through RoamingCabbage. Company neither owns nor controls the third-party websites and applications accessible through RoamingCabbage. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third-party, or using a third party application, whether by means of a link on RoamingCabbage, directly through RoamingCabbage, or otherwise, and before providing any Personally-Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in those users’ discretion, protect their privacy.

SECURITY

We take security of your Personally-Identifying Information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse.  However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures.

PRIVACY POLICY CHANGES

Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to its Privacy Policy. Company will always post new versions of the Privacy Policy on RoamingCabbage. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.

DO NOT TRACK POLICY

Our site does not respond to “Do Not Track” signals or mechanisms.

CONTACT

If you have any questions regarding our Privacy Policy, please contact our privacy officer at:

Privacy Officer

Roaming Cabbage, LLC (“Company”)

20 President St

Staten Island, NY 10314

Fax: 718-504-4451

Email: support@RoamingCabbage.com

Phone: 718-576-2280