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Platinum Rye, LLC: Online Privacy Notice

Last updated: November 17, 2016

We at Platinum Rye, LLC (“Platinum Rye”), respect your concerns about privacy. This Online Privacy Notice applies to personal information we obtain through this website (“Site”). This Online Privacy Notice describes the types of personal information we obtain through the Site, how we may use the information, with whom we may share it and the choices you may have regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.

Information We Obtain

We may obtain the following types of personal information when you choose to provide it through our Site:

In addition, when you visit our Site, we may collect certain information by automated means, such as cookies and web beacons. The information we obtain in this manner includes IP address, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our site, and dates and times of website visits. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain “clickstream data,” which is a log of content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Site.

Information about our cookie practices and how you can control cookies is available here. priTo the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.

How We Use The Information We Obtain

We use the information we obtain through the Site to:

In addition, we use information collected online through cookies, web beacons and other automated means for purposes such as (i) customizing our users’ visits to our Site, (ii) delivering content (including advertising) tailored to our users’ interests and the manner in which our users browse our Site, and (iii) managing our business. We also use this information to help diagnose technical and service problems, administer our Site, identify users of our Site, and gather demographic information about our users. We use clickstream data to determine how much time users spend on web pages of our Site, how users navigate through our Site, and how we may tailor our Site to better meet the needs of our users.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We may use third-party web analytics services on our Site, such as those of Google Analytics. The analytics providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the Site. The information collected through these means (including IP address) is disclosed to these analytics providers, who use the information to evaluate use of the Site. To learn more about Google Analytics and how to opt out, please visit www.google.com/analytics/learn/privacy.html.

Our Site is not designed to respond to “do not track” signals received from browsers.

Information We Share

We do not sell or otherwise share personal information about you, except as described in this Online Privacy Notice. We share personal information with third parties who perform services on our behalf. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also share the personal information we obtain with our affiliates and subsidiaries for the purposes described in the section of this Online Privacy Notice called “How We Use the information We Obtain.”

In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

Your Options

We offer you certain choices about how we communicate with you and what information we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated in the How To Contact Us section of this Online Privacy Notice.

Access and Corrections

To the extent provided by the law of your jurisdiction, you may (i) have the right to access certain personal information we maintain about you and obtain a copy of that information, (ii) update or correct inaccuracies in that information, (iii) object to our use of your personal information, and (iv) delete your personal information from our database. To exercise these rights, please contact us as indicated in the How To Contact Us section of this Online Privacy Notice. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. A charge may be applicable before we provide you with a copy of any of your personal information that we maintain.

Data Transfers

Some of the personal information we collect about you through the Site will be transferred to countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Online Privacy Notice and will comply with applicable legal requirements.

If you are located in the EEA, with respect to transfers of personal information to the U.S., Platinum Rye is self-certified under the EU-U.S. Privacy Shield framework developed by the U.S. Department of Commerce and the European commission regarding the transfer of personal information from the EEA to the U.S. Click here to view our EU-U.S. Privacy Shield Privacy Policy.

Links To Other Websites

Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with Platinum Rye. Linked websites typically have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with Platinum Rye, any use of those websites, or the privacy practices of those websites.

How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Updates To Our Online Privacy Notice 

This Online Privacy Notice will be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of the notice when it was most recently updated.

How To Contact Us

If you have any questions about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by email at PRE_Privacy@platinumrye.com or write to us at:

Platinum Rye, LLC
Attn: General Counsel
1999 Bryan Street, 18th Floor

Dallas, TX, USA 75201

 

EU-U.S. Privacy Shield: Consumer Privacy Policy

Last Updated: November 17, 2016

Platinum Rye, LLC (“Platinum Rye”) respects your concerns about privacy. Platinum Rye participates in the EU-U.S. Privacy Shield framework (“Privacy Shield”) issued by the U.S. Department of Commerce. Platinum Rye commits to comply with the Privacy Shield Principles with respect to Consumer Personal Data the company receives from the EU in reliance on the Privacy Shield. This Policy describes how Platinum Rye implements the Privacy Shield Principles for Consumer Personal Data.

For purposes of this Policy:

“Consumer” means any natural person who is located in the EU, but excludes any individual acting in his or her capacity as an Employee.

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Employee” means any current, former or prospective employee, temporary worker, intern or other non-permanent employee of any subsidiary or affiliate of Platinum Rye, who is located in the EU.

“EU” means the European Union and Iceland, Liechtenstein and Norway.

“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Fanscape in the U.S. from the EU, and (iii) recorded in any form.

“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.

“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.

“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.

“Supplier” means any supplier, vendor or other third party located in the EU that provides services or products to Platinum Rye.

Platinum Rye’s Privacy Shield certification, along with additional information about the Privacy Shield, can be found at https://www.privacyshield.gov/. For more information about Consumer Personal Data processing with respect to information obtained through Platinum Rye’s website, please visit the Online Privacy Notice.

Types of Personal Data Platinum Rye Collects

Platinum Rye collects Personal Data directly from Consumers. This collection occurs, for example, when a Consumer visits Platinum Rye’s website. The company may use this information for the purposes indicated in the Online Privacy Notice.

The types of Consumer Personal Data Platinum Rye collects includes:

In addition, Platinum Rye obtains Personal Data, such as contact information and financial account information, of its Suppliers’ representatives. Platinum Rye uses this information to manage its relationships with its Suppliers, process payments, expenses and reimbursements, and carry out Platinum Rye’s obligations under its contracts with the Suppliers.

Platinum Rye also may obtain and use Consumer Personal Data in other ways for which Platinum Rye provides specific notice at the time of collection. 

Platinum Rye’s privacy practices regarding the processing of Consumer Personal Data comply with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.

Notice

Platinum Rye provides information in this Policy and the Online Privacy Notice about its Consumer Personal Data practices, including the types of Personal Data Platinum Rye collects, the types of third parties to which Platinum Rye discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data, and how to contact Platinum Rye about its practices concerning Personal Data.

Relevant information also may be found in notices pertaining to specific data processing activities.

Choice

Platinum Rye generally offers Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the Privacy Shield Principles, Platinum Rye obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact Platinum Rye as indicated below regarding the company’s use or disclosure of their Personal Data. Unless Platinum Rye offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy. 

Platinum Rye shares Consumer Personal Data with its affiliates and subsidiaries. Platinum Rye may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. Platinum Rye also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

Accountability for Onward Transfer of Personal Data

This Policy and the Online Privacy Notice describe Platinum Rye’s sharing of Consumer Personal Data. 

Except as permitted or required by applicable law, Platinum Rye provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Platinum Rye requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (iii) notify Platinum Rye and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles. 

With respect to transfers of Consumer Personal Data to third-party Processors, Platinum Rye (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Platinum Rye’s obligations under the Privacy Shield Principles, (v) requires the Processor to notify Platinum Rye if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Platinum Rye remains liable under the Privacy Shield Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Platinum Rye proves that it is not responsible for the event giving rise to the damage.

Security

Platinum Rye takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

Data Integrity and Purpose Limitation


Platinum Rye limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. Platinum Rye does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes, Platinum Rye takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, Platinum Rye relies on its Consumers to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers may contact Platinum Rye as indicated below to request that Platinum Rye update or correct relevant Personal Data. 

Subject to applicable law, Platinum Rye retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer.

Access


Consumers generally have the right to access their Personal Data. Accordingly, where appropriate, Platinum Rye provides Consumers with reasonable access to the Personal Data Platinum Rye maintains about them. Platinum Rye also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. Platinum Rye may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’s privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting Platinum Rye as indicated below. 

Recourse, Enforcement and Liability


Platinum Rye has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. Platinum Rye conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Platinum Rye makes about its Privacy Shield privacy practices are true and that Platinum Rye’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

Consumers may file a complaint concerning Platinum Rye’s processing of their Personal Data. Platinum Rye will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact Platinum Rye as specified below about complaints regarding Platinum Rye’s Consumer Personal Data practices. 

If a Consumer’s complaint cannot be resolved through Platinum Rye's internal processes, Platinum Rye will cooperate with JAMS pursuant to the JAMS International Mediation Rules, available on the JAMS website at

 www.jamsadr.com/international-mediation-rules. JAMS mediation may be commenced as provided for in the relevant JAMS rules. The mediator may propose any appropriate remedy, such as deletion of the relevant Personal Data, publicity for findings of noncompliance, payment of compensation for losses incurred as a result of noncompliance, or cessation of processing of the Personal Data of the Consumer who brought the complaint. The mediator or the Consumer also may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over Platinum Rye. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Platinum Rye’s compliance with the Privacy Shield Principles.

How to Contact Platinum Rye


To contact Platinum Rye with questions or concerns about this Policy or Platinum Rye’s Consumer Personal Data practices:

Write to:

Platinum Rye, LLC

Attn: General Counsel

1999 Bryan Street, 18th Floor

Dallas, Texas, USA 75201

Or

E-mail:

 
 

PRE_Privacy@platinumrye.com