Legal

Privacy Policy

At Ruggable, we take your privacy seriously. Please read the following to learn how we treat your Personal Data.  This Privacy Policy explains our privacy practices for Ruggable.com, the Ruggable app, and the services and events (collectively, the “Services”) provided by Ruggable LLC (“Ruggable,” “we,” or “us”).  

By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

Remember that your use of Ruggable’s Services is at all time subject to the Terms of Service, which incorporates this Privacy Policy.  Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service. 

1. What this Privacy Policy covers
2. What Personal Data we collect
3. Purposes for which we collect and use your Personal Data
4. Sources from which we collect your Personal Data
5. Who we share your Personal Data with
6. Links
7. Your choices about how we use your Personal Data
8. Your Rights
9. Notice to California Residents Regarding Your Privacy Rights, including how to request that we not “sell” your personal information by clicking Do Not Sell My Personal Information
10. Nevada privacy rights
11. Your Canadian privacy rights
12. Data security and retention
13. Children’s Personal Data
14. Changes to this Privacy Policy
15. Contact us

1. What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather about you anywhere this Privacy Policy is posted, including when you access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information", "personal information" or “personal data” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't engage, and this Privacy Policy does not apply to Personal Data that we collect from our employees or contractors.

2. What Personal Data We Collect

The following chart details the categories of Personal Data that we (and the vendors we use to perform services on our behalf) collect, use, and disclose.

 

3. Purposes for Which We Collect and Use Your Personal Data

We collect and use the above categories of Personal Data for the following business and commercial purposes:

• To meet or fulfill the reason you provided the information to us.
• To communicate with you about the Services, including Services announcements, updates or offers.
• To provide the Services, including support and assistance for the Services.
• To create and manage your account or other user profiles.
• To send you marketing materials, including information about promotions, discounts, and new products.
• To personalize website content and communications based on your preferences.
• To serve you targeted offers and ads.
• To process orders or other transactions.
• To respond to user inquiries and fulfill user requests.
• To improve and develop the Services and other products and services, including testing, research, analysis and product development.
• To protect against, deter, respond to, or investigate fraudulent, illegal or harmful actions, and to maintain the safety, security and integrity of our Services.
• To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Service.
• To verify your identity in relation to requests you make about your Personal Data.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• For any other business purpose we disclose to you or as otherwise set forth in applicable data privacy laws.

4. Sources From Which We Collect Your Personal Data

We collect the above categories of Personal Data about you from various sources, directly and indirectly, including from the following: 

• We collect Personal Data directly from you – For example, when you create an account, make a purchase, participate in a promotion, contact us, sign up for our emails, submit a review, participate in our referral program, or otherwise provide information to us. 
• We collect Personal Data automatically from your devices – The Services use a variety of methods, such as cookies, beacons, and pixel tags to enable us and other parties to automatically collect information about you in connection with your use of our Services, such as when you interact with our websites, our ads, our other digital content, or our email messages. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own tracking tools on your device(s).  To learn more about your choices for these tracking tools, see the Your Choices About How We Use Your Personal Data section below. We use the following types of Cookies: 
• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you and remember your preferences.
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.
• Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. 
• Email Cookies.  Email Cookies measure the effectiveness of our email communications and allow us to tailor email content. 
• We collect Personal Data from other parties, which may include:
• Service providers. For example, we may get information from analytics service providers who analyze how you interact and engage with the Services, or from vendors that host or maintain our websites or send emails for us. We may also get information from vendors that provide customer support on our behalf. Our due diligence vendors may also give us information.
• Social networks connected to the services. If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your account with us.
• Advertising and business partners. We may receive information about you from our marketing agencies, advertising technology vendors, and other companies who assist us with marketing or promotional services related to how you interact with our websites, products, services, advertisements or communications.
• Others. We may also offer features that let your friends give us your information.  For example, your friends may provide us with your email through our Refer-a-Friend program or when they purchase an item for you as a gift.
• We combine information from different places – We may combine information that we have collected offline with information we collect online. Or we may combine information we get from another party with information we already have. We may also aggregate your information with other consumers’ information to understand preferences and trends over time.

5. How We Disclose Your Personal Data

To the extent permitted by law, each of the above categories of Personal Data we collect may be disclosed to the following categories of parties:

• to other companies in the Ruggable group from time to time;
• to service providers who provide services to us, such as website hosting, data analysis, payment processing, email delivery services, credit card processing, staff augmentation and contract personnel, auditing services, and other services related to the operation of our business, to enable them to provide services and for purposes described in this Privacy Policy;
• to a potential acquirer or receiver in the event of any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, or to another company if there is a change to our corporate structure. We may also share your information with others as they conduct diligence;
• to strategic partners with whom we may enter into a relationship for promotional activities or for business opportunities;
• to third parties in connection with co-branded campaigns or joint marketing initiatives, or in connection with certain promotions or sweepstakes you may participate in. To the extent that the promotion’s rules concerning the treatment of your Personal Data are stricter than this Privacy Policy, the promotion’s rules apply;
• to companies that assist with or deliver our online and email advertisements, such as social media platforms, advertising networks, and ad tech companies;
• to judicial, governmental, investigatory, or regulatory entities and other parties in order to comply with the law or to protect ourselves, our customers, or others, such as pursuant to a court order, subpoena, or government or law enforcement investigation, or in relation to the investigation, prevention, or remediation of actual or suspected fraud or other wrongdoing, or to enforce, establish, exercise, defend or apply our agreements or legal claims, or to protect our rights or the rights of others;
• to our online and email advertisers and other vendors who may provide cookies or other similar technologies for use on our website or in our emails; or
• as otherwise described to you from time to time or as permitted or required by law.

6. Links

The Services may link to third-party websites from companies other than Ruggable, such as to relevant online resources, our partners’ websites, payment processors, and other third-party websites. We are not responsible for the privacy practices or content of such other websites. If you have any questions about how these other websites use your information, you should review their policies and contact them directly. We are not responsible for the actions of third parties.

7. Your Choices About How We Use Your Personal Data

You can opt out of receiving our marketing emails and text messages. As noted above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive promotional emails from us, please indicate your preference by following the instructions in any promotional email you get from us, or by emailing us at support@ruggable.com.  To opt out of our text messages, reply “STOP.”

You can control certain cookies and tracking tools. Your browser can help you manage cookies. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings on each browser and device that you use. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to many features that make our Services more efficient, and some of our Services will not function properly. We also use Google Analytics to better understand how our users interact with our websites. You can learn about Google Analytics’ currently available opt-outs at https://tools.google.com/dlpage/gaoptout/.

You can control certain tracking for the purpose of serving interest-based advertising. We and third party advertising networks, social media companies, and other services may collect information about your use of our websites over time and across devices, using cookies or other tracking tools, for the purpose of displaying interest-based advertising. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technologies, ad servers, ad networks or any other non-affiliated third parties.   

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative's (“NAI”) Consumer Opt-Out Link and/or the Digital Advertising Alliance's (“DAA”) Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI's and DAA's websites, accessible by the above links.

When using a mobile application you may also receive tailored in-application advertising content. Each operating system--iOS for Apple devices, Android for Android devices, and Windows for Microsoft devices--provides its own instructions on how to prevent the delivery of tailored in-application marketing content. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertising. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.

Our Do Not Track Policy. Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our website may not work. If you block or reject cookies, not all of the tracking described here will stop.  Please note that Do Not Track is a different privacy mechanism than the Global Privacy Control browser choice referenced below.

8. Your Rights

In addition to the choices described above, the laws of your jurisdiction (including Colorado, Virginia, Connecticut, and Utah) may provide you with certain rights as to your personal data.  Applicable law may permit you to request that we:

• Confirm whether or not we are processing your personal data and provide you with access such personal data;
• Correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data;
• Delete your personal data;
• Provide you a copy of personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business, where our processing is carried out by automated means; and
• Opt you out of the processing of the personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.

If would like to exercise any of these rights, you can email us at privacy@ruggable.com, or submit a form at this address: preferences.ruggable.com/privacy.

You will be required to verify your identity before we fulfill your request. To do so, you will need to respond to the verification email sent to the address associated with the deletion request or verify as otherwise directed by us. 

We may use your personal data to send you targeted advertising.  Targeted advertising (as defined by applicable law) is advertising based on a consumer’s personal data obtained from the consumer’s activity across websites to predict the consumer’s preferences or interests.  To opt out of targeted advertising, please visit this link: Do Not Sell Or Share My Personal Information.

If we deny your request to exercise any of the rights above, you may appeal that denial by sending an email to privacy@ruggable.com describing in detail why you believe the denial was in error. Your description must include your full name and the email address used for your account with Ruggable along with a copy of the denial notice you received from Ruggable. 

9. Notice to California Residents Regarding Your Privacy Rights

If you’re a California resident, the California Consumer Privacy Act (“CCPA”) requires us to disclose information regarding the categories of personal information and sensitive personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties to whom we disclose personal information.

Throughout this Policy, we describe the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we share it. Under the CCPA, we also have to provide you with the "categories" of personal information and sensitive personal information we collect.  The categories of personal information and sensitive information that we collect are: identifiers (such as name, address, and email address); commercial information (such as transaction data); financial data (such as credit card and other financial account information); internet or other network or device activity (such as IP address); geolocation information; inference data about you; audio and visual information (such as when you call into customer service), legally protected classifications (such as your gender), and other information that identifies or can be reasonably associated with you.  The categories of sensitive personal information are account log-in and password or other credentials allowing access to your account.

We or our service providers collect and disclose the above categories of personal information for the purposes described in our Policy. This includes the following business and commercial purposes (as those terms are defined in applicable law):

• Provide the Services (e.g., account servicing and maintenance, order processing and fulfillment, customer service, advertising and marketing, analytics, and communication about the Services);
• Operational purposes (e.g. to enable and troubleshoot our Services);
• Auditing consumer interactions on our site (e.g., measuring ad impressions);
• Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
• Bug detection, error reporting, and activities to maintain the quality or safety of our Services;
• Short-term, transient use, such as customizing content that we or our service providers display on the Services;
• Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
• Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third-party partners;
• Other uses about which we notify you.

We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Services; (3) affiliates; and (4) third parties such as other users and social networks.

We describe our information disclosure practices in the Policy above. We may disclose certain categories of personal information to third parties (as defined by the CCPA) for the business purposes described above. For example, we may disclose identifiers (such as name, address, and email address) with our marketing partners in connection with co-branded campaigns, joint marketing initiatives, promotions, or sweepstakes. 

Right of California Consumers

If you’re a California resident, you may have certain rights:  

• Access – You have the right to request certain information about our collection and use of your Personal Data. You may request:
• The categories of Personal Data that we have collected or disclosed about you.
• The categories of sources from which that Personal Data was collected.
• The categories of Personal Data we sold, shared, or disclosed.
• The business or commercial purpose for collecting, selling, or sharing your Personal Data.
• The categories of third parties to whom we have disclosed or sold your Personal Data, or with whom we’ve shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.
• Deletion – You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request. 
• Correction – You have the right to request that we correct inaccurate Personal Data that we have about you.

Exercising Your CCPA Rights

To exercise the CCPA rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (e.g., an email address associated with your account or purchase history, to which we can send a verification request), and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. We will take reasonable steps to verify your identity prior to responding to your requests in accordance with applicable California law. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us. You do not need an account to submit a valid request.

California residents may submit a request using the following methods:

• Emailing us at: privacy@ruggable.com 
• Submitting a form at this address: preferences.ruggable.com/privacy

 You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization for the agent to act on your behalf. You will still need to verify your identity directly with us.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. 

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA 

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.

Do Not Sell 

The CCPA requires businesses that “sell” personal information, as the term “sell” is defined under the CCPA, to provide an opt-out from such sales. Some people have taken the position that when a website uses third parties’ cookies or similar technology for its own analytics or advertising purposes, the website is engaged in a “sale” under the CCPA if the third parties have some ability to use, disclose or retain the data to improve their service or to take steps beyond the most narrowly drawn bounds of merely providing their service to the website/app. Some take this position even when the website pays the third party (not vice versa), and in most cases merely provides the third party with an opportunity to collect data directly, instead of providing personal information to the third party. As part of these analytics and advertising services, these technologies may access identifiers (like IP addresses), internet or other electronic network activity information (like information regarding an individual’s browsing interactions on our website or app), and commercial information (like the fact that a browser visited a page directed to people who are considering purchase of a rug) to those sorts of companies. You can opt out of these activities by visiting this link: Do Not Sell Or Share My Personal Information.  You can also opt out of the sale of your Personal Data by emailing us at privacy@ruggable.com.

Do Not Share

The CCPA also requires businesses that "share“ personal information to provide an opt out from such sharing.  Under the CCPA, ”sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites.  We “share” information for these purposes to provide more relevant and tailored advertising to you regarding our Services.  As part of this advertising, we may "share“ identifiers (like IP addresses and email addresses), internet or other electronic network activity information (like information regarding an individual’s browsing interactions on our website or app), and commercial information (like the fact that a browser visited a page directed to people who are considering a rug) with advertising platforms and advertising networks.  To opt out of such “sharing,” please visit this link: Do Not Sell Or Share My Personal Information. You can also opt out of the sale of your Personal Data by emailing us at privacy@ruggable.com.

Global Privacy Control

Please note that we also respond to and abide by opt-out preference signals sent through the Global Privacy Control.  Any opt out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them.  For more information on how to use the Global Privacy Control, see www.globalprivacycontrol.org.

Children Under 16

We do not knowingly “sell” or “share” the personal information of children under 16.

Sensitive Information

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes.  Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.

Retention of your Personal Data

Please see the “Data Security and Retention” section below.

Notice of Financial Incentive

We provide certain rewards or incentives for customers to create an account, provide their emails or birthday, sign up for SMS messages, refer friends and contacts, and occasionally run sweepstakes and contests where participants may provide Personal Data in return for a chance to win or compete to win certain prizes. You can opt to these incentives by taking the requested action. Your participation is completely voluntary, and you have a right to withdraw from these incentives at any time. If you decide you don’t want to participate in these financial incentives, you can refrain from taking the request actions.  

The specific reward or incentive offered, if any, is made available to you when you provide the information requested. The monetary value of the reward or incentive is a reasonable approximation of the monetary value of the information you provide us. We have arrived at this estimate based on consideration of multiple factors, including the following: (1) revenue generated by Ruggable in developing insights on our customers; (2) expenses incurred by Ruggable in operating our incentive program or sweepstakes; and (3) our reasonable assessment of revenue we may generate as a result of the referrals provided to us by our customers.

Shine the Light

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us ask whether we have disclosed your Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@ruggable.com and note “Shine The Light Request” in the subject line.

10. Nevada Privacy Rights

If you are a resident of Nevada, you have the right to opt-out of the “sale” of certain Personal Data to third parties (as defined in applicable Nevada law). You can exercise this right by contacting us at privacy@ruggable.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. 

11. Your Canadian Privacy Rights. 

If you are a resident of Canada, you have the right to refuse to provide or to withdraw your consent to processing of your Personal Data at any time with effect for future processing. This would not affect processing where the applicable law allows us to process Personal Data without consent.

Residents of Canada may also access, review, delete, and request correction of their Personal Data held by Ruggable.  We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the Personal Data and whether you have an account with us.  We reserve the right not to change Personal Data if we disagree that it is incorrect, but we will append your requested alternative information. We may not provide access to Personal Data where permitted or required to deny access by the applicable law, for example, where the information requested would disclose the Personal Data, including opinions, of another individual or if it is subject to solicitor-client or litigation privilege.  

If you are a Canadian resident, we will transfer your information to the United States, where that information may be accessible to law enforcement and national security authorities under certain circumstances.

12. Data Security and Retention

We use a variety of technical, administrative, and organizational security measures designed to maintain the safety of your Personal Data. Despite our efforts, no website, database or system is completely secure or “hacker proof.” You can help keep your data safe by taking reasonable steps to protect your Personal Data against unauthorized disclosure or misuse.

We retain Personal Data about you for as long as necessary to provide you with our Services and for the purposes described in this Privacy Policy. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally. 

13. Personal Data of Children 

The Services are not directed to children under the age of 13.  In addition, you must be 18 or over to use the Services.  We do not knowingly collect or solicit Personal Data from children under 18; if you are a child under 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If you believe that a child under 18 may have provided us Personal Data, please contact us at support@ruggable.com.

14. Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. Those changes will go into effect on the Last Updated Date shown in the revised Privacy Policy. If we make a material change to the Privacy Policy, you will be provided with appropriate notice in accordance with legal requirements.  If you use the Services after any changes to the Privacy Policy have been posted, that means you consent to all of the changes relating to the data processing described.

15. Contact Us

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, please do not hesitate to contact us at privacy@ruggable.com.