This is our Privacy Statement. This Privacy Statement has been updated May 2018 to comply with the new European Union GDPR for our European customers which fall under the jurisdiction of the new General Data Protection Regulation (GDPR).
You may view our Terms of Service Statement HERE.
It also tells you about your privacy rights and how the law protects you.
2. Our website and the CordBands LLC group of companies
Our website at RuggedRosaries.com, Cordbands.com, combatrosaries.com, and any other website owned by us that points to cordbands.com sells Catholic Religious Goods including but not limited to Rosary Beads, Jewelry, Decals, Books, Medals, and Crucifixes. This website is not intended for children and we do not knowingly collect data relating to children.
Rugged Rosaries is made up of two different legal entities:
- CordBands LLC located at 6363 Richmond Ave, Houston, TX; and
- Rugged Rosaries® located at 1518 Coffee Rd., Modesto, CA.
CordBands LLC is the corporate owner of the company dba Rugged Rosaries. Rugged Rosaries is a registered trademark Reg. No. 4,779,215. Cordbands LLC is the data controller responsible for the website and any handling of personal data carried out by or on behalf of Rugged Rosaries. Rugged Rosaries is a data controller for any handling of personal data carried out by or on behalf of Rugged Rosaries.
3. Personal data which we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect a variety of information about our wonderful customers (you!) and visitors to the Rugged Rosaries website. This personal data falls into these categories:
Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).
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.
Usage Data includes information about how you use our website, products and services.
Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
Marketing and Communications Data includes your preferences in receiving direct marketing from us.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you use any of these types of personal data on products you design or create on Rugged Rosaries.com, we will treat all the personal data included in designs or products as ordinary personal data.
If you choose not to share personal data with us, or refuse certain contact permissions, for example, an email address, we might not be able to provide the products and services you’ve asked for.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or through chat or social media.
This includes personal data you provide when you:
- sign up to receive the Rugged Rosaries emails;
- make enquiries or request information be sent to you;
- create an account on our website;
- create designs for products on our website;
- order our products or services;
- ask for marketing to be sent to you;
- engage with us on social media;
- enter a competition, promotion or survey;
- contact customer services; or
- leave comments or reviews on our products or services (please be kind!).
Automated technologies or interactions. As you interact with us, including via the Rugged Rosaries website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our adverts (including those shown on third party websites).
Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:
- Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
- Contact, Financial and Transaction Data from providers of payment and fraud prevention services;
- Identity and Contact Data from data partners; and
- Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: To ship your products to you.
5. How we use your personal data
- Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, that’s a contract.
- 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. For example, when we carry out fraud screening as part of the check-out process.
- Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.
See Explaining the legal bases we rely on to process personal data to find out more about the types of lawful basis that we will rely on to process your personal data.
6. Explaining the legal bases we rely on to process personal data
The table HERE shows you a description of all the ways we plan to use 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
We do not carry out any automated decision making.
If you ever have any questions about this, all you have to do is ask. See How to contact Rugged Rosaries about privacy below.
7. Advertising, marketing and your communications preferences
We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you and tell you about them. This is what we call direct marketing.
We may carry out direct marketing by email, phone, text or post. For example, you might have a Rugged Rosaries announcement hit your inbox or a cool promotion land on your door mat.
Of course, there are lots of different ways you’ll see adverts for Rugged Rosaries which could be in print such as Catholic or Faith based magazines or publications, or could be on the internet on Social Media or Paid Ads, and not all of these are based on using personal data – sometimes we just buy good old-fashioned advertising space in the real world and websites and social media. If you see Rugged Rosaries’ adverts on websites and in social media, these may not be directed specifically at you, we might just have bid for the space. But here’s some things we may do that may be specifically directed at you:
- Emails from Rugged Rosaries or from Cordbands;
- text messages, for example with discount codes;
- promotions by post (we have not done this before but we may in the future); and/or
- phone calls, to tell you something that might be relevant to you.
We also work with partners (for example, Facebook) to try and promote the reach of our adverts and use aggragated analytics for this reason. We use Tracking Data to deliver relevant online advertising, including via websites and social media.
Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new customers of Rugged Rosaries. The cookies used for this purpose are often placed on our website by specialist organisations such as Facebook or Google – and this is also why when you’ve been on the Rugged Rosaries website, you might see one of our awesome rosaries again. This includes retargeting.
Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts (you know, before we risk becoming annoying). Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.
If you want more information about Tracking Data, in particular cookies, see Cookies below.
Almost all the cookies that relate to advertising are part of third party online advertising networks. If you’d like to read about how you can control which adverts you see online, see opt-out programs established by the Digital Advertising Alliance (United States), the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising Alliance. We do not control cookies which are set by advertising networks.
You can see from Advertising, marketing and your communications preferences above, that cookies are a tool which we (and everyone one else who operates online) uses for advertising. That is just part of why cookies are used. Generally, they are pretty clever.
Cookies help Rugged Rosaries work better and provide lots of help in the background to make the process of being a Rugged Rosaries customer a lot easier. You’d miss a lot of these things if they were gone – like things staying in your cart while you go off and look at other pages.
Other cookies collect information about how visitors use Rugged Rosaries website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how Rugged Rosaries websites work.
There are also cookies that allow Rugged Rosaries to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests (see Advertising, marketing and your communications preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
When you use Rugged Rosaries website, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It's important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.
9. Disclosures of your personal data
We do NOT share your personal data or contact data with other third parties except as outlined above or for legally required purposes or for purposes of Cordbands LLC doing business directly with you. In other words, we do not share your information with other companies or organizations so that they may use your information to advertise or contact you directly in any way.
We may share personal data with the following categories third parties:
- Service providers (such as technology service providers, payment processing and fraud prevention providers, post and courier services);
- Rugged Rosaries group companies;
- auditors and professional advisers like bankers, lawyers, accountants and insurers; and
- government, regulators and law enforcement
We share data with third parties connected to advertising, retargeting and analytics for our own business. We do not share data to third party companies conducting sales or advertising products which are sold by other companies. Please see Cookies above, including the cookie list, for more information about who those third parties are.
We require any and all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers 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.
10. Payment information
Rugged Rosaries uses third party payment processors SHOPIFY and PayPal to process payments made for products and services via the Website. We use ETSY payment processors for our products sold on ETSY’s website. We use AMAZON payment processors for our products sold on Amazon’s website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards (which are high!) and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors - Rugged Rosaries never (ever!) sees your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page. We have no access to the payment card numbers of our customers.
For PayPal we only store the tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal. We do not handle any data that identifies payments to AMAZON or ETSY.
11. International transfers
Whenever we transfer your personal data out of the EEA, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are:
- The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.
- We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).
- Where we use providers based in the Canada, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the Many of our external third-party providers are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.
12. Data security
We have in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.
13. Third-party links
14. Data retention
We will only keep 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 unauthorised 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.
We also make a promise to you that you can come back at any time in the future and re-order products you have ordered from us in the past. So, unless you actively delete this information, we keep it, so we can keep our promise to you.
In some circumstances you can ask us to delete your data; see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
15. Your legal rights
If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:
- The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;
- The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
- The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
- The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
- The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
- The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
- Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.
These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.
If you wish to exercise any of the rights set out above, please contact us (see How to contact Rugged Rosaries about privacy).
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.
*** You may request your Personal Data by clicking HERE ***
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.
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.
16. How to contact Rugged Rosaries about privacy
*** You may request your Personal Data by clicking HERE ***
If you need help about our products and services, or our website generally, please contact us here.
17. A little request from Rugged Rosaries to you
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can do this by contacting email@example.com. Thank you.
© CordBands LLC, 2020