Last updated - June 13, 2024

RRS DATA PRIVACY POLICY

R.R Holdings Service (RRS) and its worldwide subsidiaries (“RRS,” “we”, “our”) including Precision Dialogue Marketing LLC, are committed to protecting your privacy. This privacy policy applies to data we collect when you use our websites and other online products, mobile applications, and services that link to this privacy policy (collectively, the "Services") or when you otherwise interact with us. There are various ways that you might interact with RRS, and the data you provide when doing so allows us to improve our services. By using this website (“Site”) and by supplying your details to RRS, you consent to RRS collecting and processing your data.

This privacy policy explains:

What data we collect, and why we collect it

How we use that data

How we protect that data

How you can control your data, including accessing, updating and deleting what we store

How we share or sell data collected

Data We Collect, Share and Sell

RRS may collect or record basic personal data (e.g., name, e-mail address, mailing address, phone number) which you voluntarily provide through forms on our Sites, through social media, subscription to our email alerts, electronic mail you send to us, or through other means of communication between you and RRS.

RRS only collects personal data of a more sensitive nature (e.g., social security or other governmental ID numbers, credit card details, account numbers and audio/video recordings) where it is appropriate or necessary for conducting business. RRS will only collect and sell additional sensitive information (e.g., Demographic Information) that you voluntarily provide with explicit consent through participation in our email. This data will be collected, stored, accessed and processed in a secure manner. RRS may also collect general non-personal data pertaining to users of our sites, including IP addresses, source domain names, specific web pages, length of time spent, and pages accessed. This data is collected, among other things, to aggregate statistical data, facilitate system administration and improve the Site.

RRS also collects, uses, and discloses identifiable data about individual contacts for RRS's customers (“Business Contact Data”) in the ordinary course of its business for managing and maintaining customer relationships. In particular, RRS may obtain the following types of Business Contact data: name, address, invoice data including bank account data, and order data. Unless otherwise specified or prohibited, RRS may share data with affiliates, business partners, service providers, subsidiaries or contractors who are required to provide you with services which you have requested from us.

RRS may also post links to third party websites as a service to you. These third–party websites are operated by companies that are outside of our control, and your activities at those third–party websites will be governed by the policies and practices of those third parties. We encourage you to review the privacy policies of these third parties before disclosing any data, as we are not responsible for the privacy policies of those websites.

RRS Employee Information:

With regard to RRS employee data, RRS collects employee data only for legitimate business purposes, including:

Carrying out obligations under employment contracts and employment, tax and benefits laws, and in connection with other working relationships or arrangements

Employee communications, including development and training programs

Maintaining a global employee directory

HR activity including:

Managing employee compensation and performance

Managing employee hiring (including background checks, reference checks) and employee terminations

Voluntarily obtaining employee personal data about family members, including emergency points of contact

RRS Help Desk activity, including audio recordings

Physical Security based video recordings

Employee information on health, performance evaluations and other sensitive employee matters, whether it is stored manually or electronically, is accessible by other RRS employees only if necessary with respect to legitimate human resource functions or issues. Additionally, employee personal/family information is never sold, leased, or rented to any third party. RRS will obtain affirmative consent from an employee before using such employee’s personal data for any purpose other than described above.

Employee personal data will never be disclosed to third parties except as follows:

To those retained by RRS as agents for the purposes of providing requested services to RRS

Where required pursuant to an applicable law, governmental or judicial order, law or regulation, or to protect the rights or property of RRS

Where the employee voluntarily provides personal data and the context makes it clear that such data will be provided to a third party.

Where human resource data is transferred from the EU to the US in the context of the employment relationship, RRS will cooperate in investigations by and to comply with the advice of the appropriate EU authorities.

How We Use Data

RRS uses the data we collect to provide you with services which you request and to improve our existing services and the content of our Site. When you contact RRS, we may keep a record of your communication to help solve any issues that you might be facing. Depending on the country in which you live, work or access our Site(s), your data may be retained for a reasonable time for use in future contact with you, or for future improvements to RRS services. In the event the data you provide to us is an application for employment, that application will be held in accordance with our HR records management policy. You have the option to opt-out or opt-in for further communications from RRS.

RRS may also use or disclose your personal data when RRS believes, in good faith, that such use or disclosure is reasonably necessary to (i) comply with law, (ii) enforce or apply the terms of any of our user agreements, or (iii) protect the rights, property or safety of RRS, RRS users, or others. RRS reserves the right to transfer and disclose your data if RRS becomes involved in a business divestiture, change of control, sale, merger, or acquisition of all or a part of its business.

Web User Tracking – Use of Cookies

Cookies are a technology that can be used to help personalize your use of a website. A cookie is an element of data that a website can send to your browser, which may then store it on your system. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it or decline at any time. To enable RRS to access the effectiveness and usefulness of this Site, and to give you the best user experience, we collect and store data on pages viewed by you, your domain names and similar data. Our Site makes use of anonymous cookies for the purposes of:

Completion and support of Site activity;

Site and system administration;

Research and development;

Anonymous user analysis, user profiling, and decision-making.

In addition, in certain external facing RRS applications and geographical regions, you can accept or decline the use of 3rd party cookies based on your personal preferences.

Please note that when visiting our sites, RRS does not support “Do Not Track” settings with respect to browser or mobile applications. 

Security

The security of your personal data is important to us. We follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and once we receive it.

RRS uses reasonable measures to safeguard personally identifiable data, which measures are appropriate to the type of data maintained, and follows applicable laws regarding safeguarding any such data under our control. In addition, in some areas of our Sites, RRS may use encryption technology to enhance data privacy and help prevent loss, misuse, or alteration of the data under RRS’s control. RRS also employs industry-standard measures and processes for detecting and responding to inappropriate attempts to breach our systems.

Monitoring and Enforcement

RRS regularly reviews our compliance with our privacy policy. We also adhere to several self- regulatory frameworks in addition to complying with applicable law. If we receive formal written complaints, we will follow up with the person making the complaint. We work with the appropriate regulatory authorities to resolve any complaints that cannot be resolved directly.

Compliance

RRS adheres to US and other international regulations such as:

Personal Information Protection and Electronic Document Act (PIPEDA)

General Data Protection Regulation (GDPR) - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (for the purposes of Article 3(2) of that Regulation.

ePrivacy Directive (ePD) - Privacy and Electronic Communications Directive (2002/58/EC)

Directives (as amended)

California Consumer Protection Act - AB-375 (CCPA)

Consistent with the spirit of International Privacy Regulations, RRS aims to resolve complaints about our collection or use of your personal data at no cost to the individual. However, as permitted by applicable Privacy Regulations, RRS reserves the right to seek compensation for requests that are unfounded, impose an excessive burden or have a repetitive character. 

PIPEDA (Canada)

RRS recognizes and has controls in place to ensure that the privacy of personal data about an "identifiable individual" used in the course of "commercial activity" is protected and managed in such a manner which meets or exceeds the guidelines set out in PIPEDA and applicable provincial legislation.

GDPR and the Standard Contractual Clauses (European Union, Switzerland and United Kingdom)

RRS uses Standard Contractual Clauses (SCCs) and internal assessments to ensure that appropriate data safeguards can be used as a ground for data transfers from the EU, Switzerland, and UK to third countries. These clauses have been “pre-approved” by the European Commission under the GDPR for data transfers from controllers or processors in the EU/EEA (or otherwise subject to the GDPR) to controllers or processors established outside the EU/EEA (and not subject to the GDPR).

RRS may obtain in the US the following types of EU, UK and Swiss information: name, address, invoice information including bank account information, and order information (“EU, UK and Swiss Business Contact Information”). RRS uses EU, UK and Swiss Business Contact Information for the following purposes: managing customer relationships, managing orders, tracking payments and ensuring payment, and otherwise maintaining the customer relationship. RRS may disclose EU, UK and Swiss Business Contact Information to its affiliates, subsidiaries, business partners, and service providers for the purposes listed above.

In situations where RRS discloses (i.e., onward transfers) EU, UK and Swiss Business Contact Information to any third parties acting as service providers or “agents” on behalf of RRS, RRS will require the recipient to protect the disclosed EU, UK and Swiss Business Contact Information in accordance with the Standard Contractual Clauses, or otherwise take steps to ensure that the EU, UK and Swiss Business Contact Information is appropriately protected. With respect to any sharing of EU, UK and Swiss Business Contact Information for the purposes of marketing RRS products and services, RRS obtains guarantees from its affiliates, subsidiaries and business partners that such entities will use and disclose such EU, UK and Swiss Business Contact Information for purposes of marketing RRS products and services only. In cases of onward transfer of EU, UK or Swiss Business Information to third parties pursuant to Standard Contractual Clauses, RRS is potentially liable in the event of an improper disclosure. In certain situations, individuals may seek to opt-out of disclosures of their EU, UK and Swiss Business Contact Information by contacting RRS as specified in the “Contacting RRS” section below.

RRS takes appropriate technical and organizational measures to safeguard EU, UK and Swiss personal data against unauthorized or unlawful processing of, or accidental loss, damage, misuse, unauthorized access, unauthorized disclosure, unauthorized alteration, or destruction, and maintains reasonable procedures to help ensure that such information is relevant for its intended use, accurate, complete, current and not excessive and that such information is not retained longer than is reasonably necessary.

With respect to personal data received or transferred pursuant to the Standard Contractual Clauses, RRS is subject to the regulatory enforcement powers of the United States Federal Trade Commission. In certain situations, RRS may disclose EU, UK and Swiss personal data as necessary in connection with the sale or transfer of all or part of its business, where required or permitted by law, where RRS believes that such disclosures are appropriate in connection with a law enforcement request or as otherwise permitted by the Standard Contractual Clauses, or in order to investigate, prevent or take action regarding illegal activities or suspected fraud or in order to comply with, enforce or apply RRS agreements.

While RRS has certified its adherence to and continues to comply with the EU-US Privacy Shield framework, RRS no longer relies on Privacy Shield as a legal basis for cross-border transfers of personal data from the EU to the US, and instead utilizes SCCs and internal assessments for such as described above.

European Union, UK and Swiss individuals with inquiries or complaints regarding our Privacy policy should contact the RRS Privacy point of contact - at DataPrivacy@myrrscorp.com RRS will respond to your inquiry within 45 days.

In the event of a reported complaint that RRS does not resolve itself, RRS commits to cooperate with the EU Data Protection Authorities (DPA’s) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by the EU DPA panel or Swiss Commissioner with regard to human resource and non-human resource data transferred from the EU,UK and Switzerland to RRS in the United States (US).

Data Processor Activities

RRS operates as a data processor for our business customers located in the US, EU, UK and other geographic locations worldwide. RRS’s business customers remain the data controllers with respect to any Customer data that they provide to RRS for our provision of services. RRS therefore acts in accordance with the instructions of such customers regarding the collection, processing, storage, deletion and transfer of Customer data, as well as other matters such as the provision of access to and rectification of this Customer data.

Children’s Online Privacy Protection – COPPA

RRS does not sell its services to children. As such, our Sites are designed for adult user interaction. We do not intentionally collect personally identifiable data from children under the age of 13.

Accessing and Updating Your Personal Data

If you have provided RRS with your personal data you have various rights:

If you are a data subject based in the EU (and to the extent that Article 3(2) of Regulation (EU) 2016/679 (GDPR) of the European Parliament and of the Council of 27 April 2016 applies to you) and where we control your data you have the right:

(in certain circumstances) to erasure of personal data (and to therefore be forgotten);

to data portability;

to launch a complaint with the office of the Information Commissioner;

to inspect the data stored by RRS for accuracy;

to have the option to opt-out or opt-in for further communications from RRS

via Subject Access Request, to know whether or not we are processing your personal data, the nature of that personal data and the purposes of the processing.

If you are a consumer based in California, US (and to the extent the CCPA applies to you), and where we control your data, you have the right, once your request has been verified:

To request disclosure of personal information collected about you

(in certain circumstances) to the deletion of your personal data

(where applicable) to the right to opt-out of the selling of your personal data

To the right of nondiscrimination for exercising your rights

A summary of 2020 CCPA request metrics can be found here.

Where the above does not apply to you, you may have the right to inspect the data stored by us for accuracy, or may request that the data be removed from our files. RRS will make a reasonable effort to comply with such requests except where it would require a disproportionate effort (for example, developing a new system or changing an existing practice). We will require that you verify your identity before we act on a request to edit or remove your data. Please direct any questions about your data to RRS by sending an inquiry to the appropriate contact in the “Contacting RRS” section below.

Changes to this Privacy Policy

RRS may change this privacy policy from time to time. If this privacy policy changes, the revised privacy policy will be posted at the “Privacy Policy" link on the Site’s home page. Your continued use of the Site constitutes acceptance of such changes in the privacy policy, except where further steps are required by applicable law.

Contacting RRS

In North America, the EU, UK and the rest of the world excluding The Philippines, questions regarding RRs’s Privacy Policy, including access and deletion requests, should be directed to RRS at dataprivacy@myrrsinc.org or by calling 1-877-RRS-4311.

In the Philippines, please direct questions to the Data Protection Officer - Philippines at DataPrivacyPH@myrrsinc.org.