Data Privacy Policy


1. Important information and contact information

Purpose of this privacy notice

This privacy notice aims to give you information on how Robertson Marketing Group, Inc. and its subsidiaries (collectively referred to as “Robertson Marketing” or "we", "us", or "our") collect and process your personal data through your use of our site, including any data you may provide through our site, such as when you sign up to our newsletter, purchase a product, or register an account with us.

If you are younger than 18 years of age

Our site is not intended for children and we do not knowingly collect data relating to children.

If you are younger than 18 years of age, you do not have permission to access or use our site, including to sign up to our newsletter, purchase a product, or register an account with us. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Robertson Marketing contact details

Our full details are:
Full name of legal entity: Robertson Marketing Group, Inc.
Email address: [email protected]
Postal address: 359 Kessler Mill Rd, Salem, Virginia 24153 U.S.A.

Should you have any concerns, we would appreciate the chance to deal with them directly. If you would like to speak to us regarding any concerns you have, please contact us by email at [email protected]. 

If you are a resident of the United States you have the right to make a complaint at any time to the attorney general office in your home state.

If you are located in the United Kingdom

Robertson Marketing has an establishment in the United Kingdom (UK) and intends to comply with the UK General Data Protection Regulation (UK GDPR) if it is applicable to you. If you are located in the UK, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the United Kingdom supervisory authority for data protection issues.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

If you are located in the European Economic Area

Robertson Marketing has an establishment in The Netherlands and intends to comply with the European Union’s General Data Protection Regulation (GDPR) if it is applicable to you. If you are a located in a country in the European Economic Area (EEA), you have the right to make a complaint at any time to the Dutch Data Protection Authority (DDPA), The Netherlands supervisory authority for data protection issues (https://autoriteitpersoonsgegevens.nl/en).

The DDPA’s address:

Autoriteit Persoonsgegevens
PO Box 93374
2509 Aj Den Haag

Telephone number: (+31) - (0)70 - 888 85 00
Fax: (+31) - (0)70 - 888 85 01



2. The data we collect about you

We may collect, use, store transfer, or otherwise process different kinds of personal data that you give us through our site, , which we have categorized as follows:

  • Identity Data includes first name, middle name, maiden name, last name, username or similar identifier.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes payment card details.
  • Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
  • Technical Data includes 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 technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you.
  • Usage Data includes information about how you use our site and products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us or our third parties and your communication preferences. Please keep us informed if your personal data changes during your relationship with us.
  • Aggregated Data includes statistical or demographic data for any purpose. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data and it will be used in accordance with this privacy notice. Otherwise, we will not treat Aggregated Data as personal data because it does not directly or indirectly identify you.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, gender, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We also do not collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal under the terms of a contract you intend to make with us, and you fail to provide that data when requested, we may not be able to perform the contract, for example, to provide you with products. In this example, we may be unable to process an order for a product or we may have to cancel the order, but we will notify you if this is the case at the time.



3. How is your personal data collected?
  • Direct Interactions. You may give us your Identity Data, Contact Data, and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • create an account on our site;
    • place an order for our products;
    • subscribe to our newsletters;
    • request marketing to be sent to you; or
    • give us some feedback, including in connection with product reviews.
  • Automated Technologies or Interactions. As you interact with our site, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other sites employing our cookies. Please see below for further details on cookies.
  • Third Parties or Publicly Available Sources. We may receive personal data about you from various third parties as set out below:
    • Technical Data from the following parties: analytics providers such as Google; and
    • Contact Data, Financial Data, and Transaction Data from providers of technical, payment, and delivery services, from your employer, or from a business contact.


4. How we use your personal data

Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with 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, including from law enforcement; or
  • to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.

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

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate (please see paragraph 10 (Glossary) for a definition of legitimate interest).

Note that we may process your personal data on 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 basis we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity Data
(b) Contact Data

Performance of a contract with you (please see paragraph 10 (Glossary) for a definition of performance of a contract)

To process and deliver your order including:
(a) Calculate and process charges and payments
(b) To calculate and report sales and value added taxes

(c) Collect and recover money owed to us

(a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Marketing and Communications Data

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (such as to report and pay sales and value-added taxes)
(c) Necessary for our legitimate interests (such as to collect and recover money owed to us)

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave feedback, such as a product review, or take a survey

(a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Marketing and Communications Data

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (such as to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity Data
(b) Contact Data
(c) Technical Data

(a) Necessary for our legitimate interests (such as for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation (please see paragraph 10 (Glossary) for a definition of comply with a legal or regulatory obligation)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical Data
(b) Usage Data

Necessary for our legitimate interests (such as to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity Data
(b) Contact Data
(c) Technical Data
(d) Usage Data
(e) Profile Data

Necessary for our legitimate interests (such as to develop our products/services and grow our business)

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Promotional offers from us

We may use your Identity Data, Contact Data, Technical Data, Usage Data, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing). You will receive marketing from us if you have requested information from us or purchased goods from us and, in each case, you have opted-in to receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside Robertson Marketing for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving marketing, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience, or other transactions.



5. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this bsite may become inaccessible or not function properly.

About cookies

A cookie is a file containing an identifier (such as a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. Cookies can be used by web servers to identity and track users as they navigate different pages on a website and identify users returning to a website.

Our cookies

We use both session and persistent cookies on our website. The names of the cookies that we use on our website, and the purposes for which they are used, are set out below. We use cookies on our site to recognize a computer when a user visits the site / track users as they navigate the site / enable the use of a shopping cart on the site / improve the site's usability / analyze the use of the site / administer the site / prevent fraud and improve the security of the site / personalize the site for each user.

Analytics cookies:

We use Google Analytics to analyze the use of our site. Google Analytics generates statistical and other information about website use by means of cookies. The analytics cookies used by our site have the following identifiers in their names: _utma, _utmb, _utmc and _utmz. The information generated relating to our site is used to create reports about the use of our site. Google Analytics privacy policy is available at: http://www.google.com/policies/privacy/.

Third party cookies:

Our site does not use third party cookies in addition to analytics cookies.

Blocking cookies:

Most browsers allow you to refuse to accept cookies; for example:

  • In Microsoft Edge you can block cookies using the cookie handling override settings available by clicking …(Setting and more), then settings, the Cookies and site permissions, then Manage and delete cookies and site data and tuning on the block third party cookies option.
  • In Firefox, click on the hamburger menu, and then choose Options, Click Privacy & Security in the left panel, and select Custom beneath the "Enhanced Tracking Protection" heading. In the dropdown next to Cookies, choose the types of cookies you want to block: Cross-site cookies , Cookies from unvisited websites , All third-party cookies, or All cookies.
  • In Chrome, you can block all cookies by accessing the "Customize and control" menu (three vertical dots), and clicking "Settings", then selecting Privacy and security, then selecting Cookies and other site data. and then selecting "Block third party cookies or Block all cookies. Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

Deleting cookies:

You can delete cookies already stored on your computer; for example:

  • In Microsoft Edge, select Menu (3 dots icon on top right corner of the browser) > Settings > Privacy & services. Under Clear browsing data, select Choose what to clear, Select "Cached images and files" and "Cookies and other site data" check box and then select Clear.
  • in Firefox, you can delete cookies by clicking In the Menu bar at the top of the screen, click Firefox and select Preferences. Click the menu button. and select Settings. Select the Privacy & Security panel and go to the Cookies and Site Data section. Click the Clear Data… button. The Clear Data dialog will appear. ... Click Clear.
  • In Chrome, you can delete all cookies by accessing the "Customize and control" menu (three vertical dots), and clicking "Settings", then selecting Privacy and security, then selecting Clear browsing data and then selecting “Cookies and other site data”. Deleting cookies will have a negative impact on the usability of many websites.

List of Cookies Managed by Our Website may include


Cookie Name

Cookie Description

FORM_KEY

Stores randomly generated key used to prevent forged requests.

PHPSESSID

Your session ID on the server.

GUEST-VIEW

Allows guests to view and edit their orders.

PERSISTENT_SHOPPING_CART

A link to information about your cart and viewing history, if you have asked for this.

STF

Information on products you have emailed to friends.

STORE

The store view or language you have selected.

USER_ALLOWED_SAVE_COOKIE

Indicates whether a customer allowed to use cookies.

MAGE-CACHE-SESSID

Facilitates caching of content on the browser to make pages load faster.

MAGE-CACHE-STORAGE

Facilitates caching of content on the browser to make pages load faster.

MAGE-CACHE-STORAGE-SECTION-INVALIDATION

Facilitates caching of content on the browser to make pages load faster.

MAGE-CACHE-TIMEOUT

Facilitates caching of content on the browser to make pages load faster.

SECTION-DATA-IDS

Facilitates caching of content on the browser to make pages load faster.

PRIVATE_CONTENT_VERSION

Facilitates caching of content on the browser to make pages load faster.

X-MAGENTO-VARY

Facilitates caching of content on the server to make pages load faster.

MAGE-TRANSLATION-FILE-VERSION

Facilitates translation of content to other languages.

MAGE-TRANSLATION-STORAGE

Facilitates translation of content to other languages.

_gid

Google Analytics

_ga

Google Analytics

_AntiXsrfToken

To help prevent cross site scripting attacks

SessionID

To maintain identification of the user between page requests

PEPS.miltonuref

Application reference identifier

PEPS.miltoneref

Application reference identifier

PEPS.miltonbasket

User shopping cart identifier

.MiltonPEPS

Help maintain information between page requests


6. Disclosures of your personal data

We may have to share your personal data with the categories of recipients set out below for the purposes set out in the table in paragraph 5 above.

  • Legal entities within Robertson Marketing, and to our employees, contractors, and agents.
  • Technical services vendors, such as providers of e-commerce, order management, and warehouse management solutions
  • Product suppliers (for example, if they ship a product directly to you)
  • Sales or value-added tax calculation and reporting companies
  • National, regional, and local government authorities, such as tax authorities and law enforcement
  • Delivery companies to deliver your order
  • Payment solutions providers
  • Procurement and supply chain solution providers required by our customers (such as when you receive a gift from your employer)
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require recipients of your personal data to respect the security of your personal data and to treat it in accordance with the law. We do not allow our recipients to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

Please note, however, that we cannot impose any requirements on any government authorities, such as tax authorities. Restrictions on the use of your personal data by government authorities are established by law.



7. International transfers

We share your personal data with other members of Robertson Marketing and between countries in which we operate. This will involve transferring your data outside your home country, including to some countries outside of the EEA that do not have an adequate level of protection for personal data approved by the European Commission. However, where we use certain service providers (as per paragraph 6), we may use specific contracts and other mechanisms approved by the European Commission which give personal data the same protection it has in the Europe Union. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.



8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.



9. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements



10. Your legal rights

Marketing

We will inform you (before collecting your data) if we intend to use your data for marketing purposes. We will only use your data for this if you have opted-in.

Correction of information

If you notify us that the personal data we hold is incomplete or inaccurate we will complete or correct the information as soon as practicable.

Deletion of information

You have the right to request that your personal data be deleted; including if we no longer need it for the purpose we collected it, or, where our legal basis for processing is that you have given consent, you withdraw your consent.

Following such a request we will erase your personal data without undue delay unless continued retention is necessary and permitted by law. If we made the personal data public, we will take reasonable steps to inform other data controllers processing about your erasure request.

Object to processing

You have the right to object to us processing your personal data where we are relying on a legitimate interest basisand 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 interests to process your information which override your rights and freedoms.

Restriction on processing

You have the right to request that we suspend processing your personal data, but hold it for you, in the event the personal data we hold is inaccurate, the processing is unlawful or we no longer need the personal data. Once the processing is restricted, we will only continue to process your personal data if you consent or we have another legal basis for doing so.

Access to information

You have the right to access information held about you and any access request will usually be free of charge. We will endeavor to provide information in a format requested, but we may charge you a reasonable fee for additional (duplicate) copies.

Data Portability

You have the right to receive a copy of your personal data which you gave to us. The copy will be provided in a commonly used and machine-readable format. You can also have it transmitted directly from us to another data controller, where reasonably technically possible. 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.

Withdraw consent at any time

You may withdraw your 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 or any processing carried out where we rely on another basis, such as legitimate interest or compliance with a legal obligation, to conduct the processing. 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.

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.



11. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.



12. Other Terms

Changes to policy

We reserve the right to change this policy at any time. Any changes in the future will be posted on this page. The date of the latest update to this privacy policy is set out at the top of this policy.

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.




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