Privacy Policy
Rokimoto.com Privacy Policy
Funmaker Inc. ("Company" or "We") respects your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website Rokimoto.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.
1.Who is responsible for your data?
This policy governs any kind of processing of personally identifiable information about natural persons (“personal data”) in connection with the provision of Rokimoto products or services, by Funmaker Inc., and all entities within the corporate group. This policy applies to our processing of personal data collected through any means, actively as well as passively, online (including through your use of our websites (collectively “Sites”), as well as offline, such as at our events. For the purpose of the UK/EU data protection legislation, the data controller responsible for processing your personal information is Funmaker Inc.
This Privacy Policy provides you with information on how Funmaker Inc. collects and processes your personal data through your use of any of our and the products and services we offer (“Products and Services”).
Additional disclosures apply if you live in the following regions (please see the corresponding region-specific section below):
- California
- Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia
- Nevada
2. How to contact us
If you have any questions about this Privacy Policy, please contact us by email at support@rokimoto.com.
3. Updates to this Privacy Policy
We may need to update our Privacy Policy from time to time. If we do, we will notify you of any significant changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulation requirements. We may notify you by email of any significant changes to this Privacy Policy, but we encourage you to review this Privacy Policy periodically to keep up to date on how we use your personal data.
4. What kind of data do we collect?
We may collect and process the following personal data about you:
- Identity and Account Data, Characteristics, or Demographics, including first name, last name, username, password or similar identifier, title and gender, job title and organization you represent.
- Contact Identifiers, including billing address, delivery address, email address and telephone numbers.
- Financial, Payment, and Transaction Data, including bank account and payment card details as well as details about payments to and from you and other details of services you have purchased from us.
- Behavioral Data, including data relating to your behaviors, interests and preferences, including data collected as a result of your browsing activity and/or interaction with our Sites, Products and Services and/or our emails which is obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started.
- Technical and Usage Data, including (i) internet protocol (IP) address; (ii) browser type and version; browser plugins; (iii) device name (e.g. “Apple iPhone” or “Samsung Galaxy” or any other name that you have given your device); (iv) operating system and version; (v) system language; (vi) general device data, such as voice and regional settings (including non-precise location data); and (vii) date and time of use.
- Profile Data, including information about your interests and preferences from your use of our services (including events you have attended), demographic data information you have provided to us within your account (e.g. any personal description and/or photographs you may provide or take), enquiries about our services or other feedback and survey responses or other information you may provide, as well as interferences we may make about your interests and preferences based on other Behavioral Data or Marketing Communications Data provided.
- Marketing and Communications Data, including your preferences in receiving marketing from us and our third parties and your communication preferences.
- Professional, Employment, or Education-Related Data, including date of birth; gender; country of residence; nationality; details of your eligibility to work (including documents and information that we may collect to verify this); your work preferences (including areas and dates where you are available for work); skills, qualifications, training and work history; photographs of you; any personal data which appears in your curriculum vitae or application; and any personal data that you volunteer during an interview or your interactions with us.
- Information We Infer. We infer new information from other information we collect, including to generate information about your likely preferences or other characteristics.
5. How do we collect data?
We collect data through the following:
- Direct interactions. You may give us your personal data directly, for example, when you purchase products on our Sites, contact us with enquiries, complete forms on our websites, interact with us via social media, subscribe to receive our marketing communications, attend our events, or provide feedback to us.
- Automated technologies or interactions. As you interact with our Sites, we may automatically collect Behavioral Data or Technical and Usage Data. We collect typically collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy below for further details.
- Third party sources. We may receive personal data about you from third parties. Such third parties may include analytics providers, our third-party resellers, social media sites, business partners, Data Brokers, third party directories and third parties that provide technical services to us so that we can provide our Sites, Products and Services.
- Publicly available sources. From time to time, we may collect personal data about you (Identity Data, Contact Data or Profile Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media sites).
6.Who do we collect data from?
We collect data from the following individuals, entities, and organizations:
- Website Visitors: If you use our Site or register an account on our Site, we will collect and process your personal data in connection with your interaction with us and our Site.
- Consumers: If you buy our Products and Services or participate in our promotions or competitions, we may collect and process your personal data in connection with the supply of goods or services to you.
- Individuals that Contact us: If you contact us with an enquiry through our Sites, submit a complaint through our Sites or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal data in connection with your interaction with us and our Sites.
- Job Applicants: If you apply for a job with us, whether through Sites or otherwise, we will collect and process your personal data in connection with your application.
- Social Media Personnel: If you receive Rokimoto products from us and display such products on your social media platform or just display our products with no prompt from us, we may process your personal data in connection with your interactions with us and such products.
7.How do we use your personal data?
We will only use your personal data when the law allows us to. We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.
The main ways we use your data are:
- to provide you with our Platforms, Products and Services;
- to deal with customer services and enquiries, carry out surveys and obtain feedback;
- to carry out insight and analysis, such as analytics and improvement;
- to personalize your shopping experience using automated decision making;
- to carry out our promotional, marketing, and advertising practices; and
- for business administration (including recruitment), security and enforcement, and legal compliance purposes.
In specific situations, we collect and process your data with your consent, for example, when you tick a box or register your email to receive email newsletters. You can withdraw this consent at any time. In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order an item for home delivery, we will collect your address details to deliver your purchase and pass them to our courier. In exceptional circumstances, if the law requires us to, we may need to pass data for law enforcement, for example, details of people involved in online fraud.
To conduct our advertising and marketing, we work with agencies, ad networks, technology providers, and other third parties to place ads about our products and services on other websites and services. For example, we may place ads through Google that you may view on their platforms as well as on other websites and services. As part of this process, we incorporate tracking technologies into our website as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities over time and across non-affiliated services and obtain or infer information about you for purposes of showing you relevant advertising based on your preferences and interests (“targeted advertising”). We may also use audience matching services (which is a type of targeted advertising) to reach people (or people similar to people) who have visited our website or are identified in one or more of our databases (“matched ads”). This is done by us providing a list of hashed email addresses to a third party or incorporating a pixel from a third party into our website, and the third party matching common factors between our data and their 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
8.When do we disclose your personal data?
When processing your personal data, we may need to disclose it with third parties (including other entities within our group of companies), as set out in the table below. We disclose your data to the multiple third parties, including but not limited to:
- Third-Party Suppliers: We disclose personal data with third parties who support us in providing our website and help provide, run and manage our internal IT systems. We disclose personal data with specialist suppliers who assist us in managing our marketing database and sending out our post and email marketing communications and account-related communications (including customer surveys and feedback requests). We also disclose your personal data with third-party service providers to assist us with insight analytics.
- Payment Providers and Banks: We disclose personal data with third parties who assist us with the processing of payments and refunds.
- Delivery Service Companies: We disclose personal data with suppliers who assist us in the delivery of our Products and Services to our consumers.
- Advertising Partners: We disclose personal data with third party advertising partners when you use our Sites to facilitate and measure any online advertising we may carry out.
- Event Partners and Suppliers: When we run events, we will disclose your personal data with third-party service providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organizations, we will disclose your personal data with such organizations for use in relation to the event.
- Accountants, Legal Counsel, and Other Professional Advisers: We disclose personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organization and in relation to any disputes we may become involved in.
- Law Enforcement and Regulatory Agencies: We disclose personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
- Other Third Parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
9.Personal Data of Minors.
Our Site is not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal data of minors. However, due to the nature of our organization and the Products and Services we provide, we may from time to time collect and process personal data relating to minors. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.
If you are under the age of 18, you must not use our Sites or purchase Products and Services from us and you must not provide us with any personal information. Please see our Website Terms of Use https://rokimoto.com/pages/terms-of-use for further details. If we discover that we are holding the personal data of a minor, we will delete that information as soon as possible. If you are a parent or guardian, please supervise your child’s use of our Sites. Please contact us if you have reason to believe that a minor may have submitted personal data to us (see the “How to contact us” section above).
10. Security of Personal Data.
We are committed to taking appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage to personal data. For example, our handling of your personal data is controlled by documented policies and procedures, including strict physical and logical access control, security back-up, failover, anti-malware protection, monitoring and vulnerability detection mechanisms.
11. Your Legal Rights as a User of this Site.
For all user, we provide the following ways for you to exercise your legal rights, as described below.
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Communications: You can opt-out of receiving certain communications from us as follows:
- Emails: To stop receiving newsletters and marketing emails, change your communication preferences through your account settings, follow the unsubscribe instructions near the bottom of such emails. Please note that you cannot opt out of transactional messages.
- SMS: To stop receiving SMS messages, text “STOP” in response to any text message you receive from us or contact us as set out in the How to Contact Us section above and specify you want to opt out of text messages.
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Browser and Device Controls:
- Preference signals: Your browser or extension may allow you to automatically transmit Do Not Track and other preference signals. Except as required by law, we do not respond to preference signals
- Third party opt-out tools: Some third parties we work with offer their own opt-out tools related to information collected through cookies and pixels. To opt out of your information being used by Google Analytics, please visit https://tools.google.com/dlpage/gaoptout. We are not responsible for the effectiveness of any third party opt-out tools.
- EU/UK Residents: To the extent our processing of your personal data falls under the requirements of the GDPR/UK GDPR, users in the EU or UK have certain rights in relation to the personal data we hold about you. Specifically, users in the EU or UK 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 for example we need to maintain your transactional data for our legal obligations to the local tax and revenue authorities.
- 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.
- 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.
d.You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. - Be excluded from automated decision making. Rokimoto has a number of different customer and consumer types who we personalize experiences for. These include self-purchasers, gift buyers, professional collectors, and more. Our personalization of your experience is achieved through automating profiling based on purchase behaviors and information shared. You can select your preference at our contact preference center, but opting out of this, you will not be able to receive any personalized inspiration or communications.
- 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.
- 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.
- To complain. If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office by telephone on 0303 123 1113 or online at www.ico.org.uk/concerns. To the extent you are located in another jurisdiction, you also have the right to lodge a complaint with the relevant data protection authority in that jurisdiction.
12. How do we retain your data?
Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected. At the end of the retention period, your data will either be deleted completely, or anonymized, so that it can be used in a non-identifiable way.
In particular, when you place an order with us, we will ordinarily keep the personal data you give us for 5 years so we can comply with our legal and contractual obligations relating to the sale of goods.
13. Region-specific provisions.
United Kingdom/European Economic Area (EEA):
Data transfers outside the United Kingdom/EEA
Where necessary in order to provide our Platforms and our Products and Services, your personal data may be accessed by and processed outside the UK and/or EEA - including by staff operating outside the UK/EEA who work for us or for one of our suppliers or agents (this includes staff engaged in, among other things, the fulfilment of your booking, ground handlers, and the provision of support services).
Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-UK/EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. For that reason, if we transfer your personal data outside the UK and/or EEA, we will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws. In particular, where required by applicable law, we will implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.
- Adequacy Decisions: We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or the UK Government (as applicable).
- Standard Contractual Clauses: Where we use certain service providers, we may use specific standard contractual clauses approved by the European Commission and/or the UK Government which give personal data the same protection it has in Europe and/or the UK.
California
This section applies solely to California “consumers” and addresses personal information we collect online and offline. This section of the Privacy Policy does not apply to Rokimoto or Funmaker Inc. personnel.
This section uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 and its implementing regulations (the “CCPA”).
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Notice at Collection
The categories of personal information we have collected in the past 12 months and the categories sources from which the personal information is collected are set out in the ‘What data do we collect?’ section above. -
Purpose
The specific business and commercial purposes for collecting and using personal information are set out in the “How do we use your data?” section above. -
Sources of Personal Information
We may obtain (and may have obtained during the 12-month period prior to the date of this privacy Policy), personal information about you from the categories of sources set out in the “How do we collect your data?” section above. -
Disclosure of Personal Information
The categories of persons to whom personal information is disclosed, including service providers for business purposes, is set out in the “When do we disclose information?” section above. We disclose the categories of personal information listed in the “What data do we collect?” section above to service providers for business purposes -
Sharing of Personal Information
Some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under California law. A “sale” is broadly defined to include a disclosure for something of value, and a “share” is broadly defined to include a disclosure for cross-context behavioral advertising. We collect, sell, or share the following categories of personal information for commercial purposes: contact identifiers, characteristics or demographics, commercial or transactions information, content, device identifiers, device information, internet activity, non-precise geolocation data, and inferences drawn from any of the above. The categories of third parties to whom we sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. We do not knowingly sell or share the personal information of minors under 16 years old who are California residents. -
Sensitive Data
Some of the personal information we collect may be considered sensitive personal information under California law. We collect, use, and disclose sensitive personal information only for the permissible business purposes for sensitive personal information under the CPRA or without the purpose of inferring characteristics about consumers. We do not sell or share sensitive personal information. -
Retention
The criteria used to determine the period of time we retain your personal information is set out in the “How do we retain data?” section above.
California Consumer Privacy Rights
You have rights to exercise choice over your personal information as follows:
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Verifiable Requests: You have the right to:
- Know what personal information we have collected about you, specifically have the right to know the categories of sources from which personal information was collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of personal information that we sold, shared, or disclosed for a business purpose, the categories of third parties to whom we disclosed personal information, and the specific pieces of personal information we have collected about you;
- Correct inaccurate personal information we maintain about you;
- Delete personal information that we have collected from you.
To exercise any of these rights, please email us at support@rokimoto.com. We will confirm receipt of and respond to your request consistent with applicable law. To verify your identity, we may require you to confirm receipt of an email sent to an email address that matches our records, provide us with details relating to your history with us, or provide additional information. If we are unable to verify your identity, we may deny your request in accordance with applicable law.
Sales and Shares: You have the right to opt-out of us selling or sharing your personal information to third parties. To exercise this right, please email us at support@rokimoto.com. Please note that when you opt-out through either of the above methods we do not know who you are within our systems, and your opt-out will apply only to information collected through tracking technologies on the specific browser from which you opt-out. If you delete or reset your cookies, or use a different browser or device, you will need to reconfigure your settings.
Shine the Light: If you are a customer, you may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To make a request, please write us at the email or postal address set out in the “Contact Us” section and specify that you are making a “California Shine the Light Request.”
Your rights to exercise choice over your personal information are subject to exceptions and our retention practices. You have the right not to be discriminated against for exercising any of your rights. To the extent permitted by law, rights requests must be exercised through the applicable designated method listed above. You may make a rights request using an authorized agent. Except for rights requests made by opt-out preference signal, we will require written and signed proof of the agent’s permission to do so and we may verify your identity directly with you.
Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia
Data Practices
For residents of Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia, our practices regarding the collection, use, disclosure, and retention of your personal data are set out in the main Privacy Policy above.
Some of our disclosures of personal data may be considered a “sale” under applicable law, which may include a disclosure for something of value. We do not process personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.
Some of the personal data we collect may be considered sensitive personal data under applicable. We collect sensitive personal data with your consent.
Requests
You have rights to exercise choice over your personal data as follows:
- Verifiable Requests: You have the right to:
- Confirm whether or not we are processing your personal data;
- Access your personal data;
- Correct inaccuracies in your personal data;
- Delete your personal data; and;
- Obtain a copy of your personal data that you previously provided to us in a portable and readily usable format:
If you are an Oregon resident, you also have the right to:
- Confirm the categories of personal data we have processed
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Receive a list of the specific third parties to which we have disclosed personal data
To exercise any of these rights, please email us at support@rokimoto.com. We will confirm receipt of and respond to your request consistent with applicable law. To verify your identity, we may require you to confirm receipt of an email sent to an email address that matches our records, provide us with details relating to your history with us, or provide additional information. If we are unable to verify your identity, we may deny your request in accordance with applicable law.
Sales and Targeted Advertising: You have the right to opt-out of us selling your personal data or processing your personal data for purposes of targeted advertising. To exercise this right, please email us at support@rokimoto.com. Please note that when you opt-out through the above method we do not know who you are within our systems, and your opt-out will apply only to information collected through tracking technologies on the specific browser from which you opt-out. If you delete or reset your cookies, or use a different browser or device, you will need to reconfigure your settings.
Your rights to exercise choice over your personal data are subject to exceptions and our retention practices. You have the right not to be discriminated against for exercising any of your rights. To the extent permitted by law, rights requests must be exercised through the applicable designated method listed above. You may make a rights request using an authorized agent. Except for rights requests made by opt-out preference signal, we will require written and signed proof of the agent’s permission to do so and we may verify your identity directly with you.
You have the right to appeal our decision in response to your request. To appeal, please write us at the email or postal address set out in the “Contact Us” section and specify what you wish to appeal. We will review and respond to your appeal in accordance with applicable law. If we deny your appeal, you may submit a complaint to your Attorney General as follows:
- For Colorado residents: https://coag.gov/file-complaint/
- For Connecticut residents: https://www.dir.ct.gov/ag/complaint/
- For Montana residents: https://dojmt.gov/consumer/
- For Oregon residents: https://justice.oregon.gov/consumercomplaints/
- For Texas residents: https://oag.my.salesforce-sites.com/CPDOnlineForm
- For Utah residents: https://attorneygeneral.utah.gov/contact/complaint-form/
- For Virginia residents: https://www.oag.state.va.us/consumercomplaintform
Nevada
Nevada residents have the right to opt-out of the sale of their information. To make a request, please write us at the email or postal address set out in the “Contact us” section and specify that you are making a “Nevada Opt Out of Sale Request.”
14. Your Comments and Concerns
We welcome any comments, concerns, or feedback you may have regarding our products, these Terms, or any of our Company policies. All feedback, comments, requests for technical support, and other communications relating to the Website should be directed to: support@rokimoto.com.