Who We Are and What We Do
This Policy applies to all of our operating divisions, subsidiaries, affiliates, and branches, and any additional subsidiary, affiliate, or branch that we may subsequently form.
Transparency & Notice - Types of Personal Information We Collect and How We Use It
Types of Personal Information We Collect
The types of Personal Information we collect and our privacy practices depend on whether you are a customer, user, visitor or Employee (together, “Individuals”) and the requirements of applicable law.
Information You Provide to Us
Communications with Us. We may collect Personal Information from you such as first name, last name, company, email address, phone number, billing address or mailing address, credit card information, request information about our Services, register for our newsletter or loyalty program, create an account, request customer or technical support, or otherwise communicate with us.
Surveys. We may contact you to participate in online surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information. All information you submit in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or Services and in any manner consistent with our policies.
Posting. We may offer fan pages, blogs, messaging or community forums. Any content you provide will be considered “public” and is not subject to privacy protections.
Automatic Data Collection. We may collect certain information automatically through our Site and Services, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, unique identifiers, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
Information from Other Sources
We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
How We Use Your Information
We Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested. We may use information about you to:
Manage Individual information and accounts;
Respond to questions, comments, and other requests;
Provide access to certain areas, functionalities, and features of our Services;
Answer requests for customer or technical support; and
Allow you to register for events.
Administrative Purposes. We may use Personal Information about you to:
Measure interest and engagement in our Site and Services;
Develop new products and Services;
Ensure internal quality control;
Verify Individual identity;
Communicate with you about your account, activities on our Site and Services and policy changes;
Contact you to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
Work with Third Parties to Process payment for products or Services purchased;
Process applications and transactions;
Prevent potentially prohibited or illegal activities; and
Enforce our Terms.
Marketing Our Products and Services. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
To tailor content, advertisements, and offers;
To notify you about offers, products, and services that may be of interest to you; and
To provide Services to you and our sponsors;
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes as described below.
Research and Development. We may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our products and Services or develop new products and Services. We may perform research via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. Survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Site and Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may use de-identified Individual and aggregated data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions below.
De-identified and Aggregated Information Use. We may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Site and Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Site and Services. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Resolüte and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Other Uses. Resolüte may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
Cookies Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Analytics. We may also use Google Analytics, Facebook, and other providers to collect information regarding visitor behavior and visitor demographics on our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. For more information regarding the collection and use of such information by Facebook, please see the Facebook Data Policy, available at: https://www.facebook.com/policy.php
Our uses of such Technologies fall into the following general categories:
Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Site and Services or on third party sites. This includes using Technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
Third-Party Websites, Social Media Platforms, And Software Development Kits
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Shop-Resolüte’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Site or other Services. We are unable to control the use of your information on social media platforms, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
We use Third-Party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and Third-Party SDKs may allow Third Parties including advertisers to collect your Personal Information to provide content that is more relevant to you.
Third-Party Payment Processing
When you make purchases through the Services, we process your payments through Third-Party payment platforms, including Shopify, Apple Pay, PayPal, Google Pay, Amazon Pay and Social Networking Sites (“SNS”) such as Facebook. The Third-Party payment platform may collect certain financial information from you to process a payment on behalf of Resolute, including your name, email address, address and other billing and shipping information.
Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. For more insight, you may also want to read Shopify’s Terms of Service (www.shopify.com/legal/terms) or Privacy Statement (www.shopify.com/legal/privacy).
Human Resources Data
Resolüte collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We Process Human Resources Data for a variety of business purposes including:
Workflow management, including assigning, managing and administering projects;
Human Resources administration and communication;
Payroll and the provision of benefits;
Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
Job grading activities;
Performance and employee development management;
Organizational development and succession planning;
Benefits and personnel administration;
Helpdesk and IT support services;
Internal and/or external or governmental compliance investigations;
Internal or external audits;
Litigation evaluation, prosecution, and defense;
Diversity and inclusion initiatives;
Restructuring and relocation;
Emergency contacts and services;
Compliance with statutory requirements;
Processing of Employee expenses and travel charges; and
Acquisitions, divestitures, and integrations.
Onward Transfer—How We May Disclose Your Information
Information We Share
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) the provision of the Site and Services. We have executed appropriate contracts with our service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Business Partners. We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Resolüte may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Resolüte. Resolüte requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Resolüte provided them.
Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Resolüte may allow Third-Party advertising partners to set tracking tools and Technologies to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit Third Party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site and Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with Third-Party advertising partners, you may follow the instructions below.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs and other records may be reviewed for security purposes – e.g., to detect unauthorized activity, illegal activity or fraud on the Site or Services. In such cases, Personal Information may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
International Data Transfers
Your Choices: Right to Object to Processing
You have the right to object to and change your preferences or opt out of certain uses and disclosures of your Personal Information. Where you have consented to Resolute’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and prevent further Processing by contacting us as described below. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Site, Services and/or information from the advertisements on Third-Party websites for other legal purposes as described above.
Email and Telephone Communications
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
We may occasionally send you push notifications or contact you through our Services, Site, social media or Third Party services with notices or alerts that may be of interest to you. You may at any time opt out or stop from receiving these types of communications by changing the settings on your mobile device.
Human Resources Data
We will use Personal Information we collect for Human Resources activities only for employment-related purposes as more fully described above. If we intend to use this Personal Information for any other purpose, we will notify the Individual and provide an opportunity to exercise their rights under applicable law.
Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may limit ad tracking of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/ and www.aboutads.info/choices/.
Rights of Access, Rectification, Erasure, and Restriction
Although Resolüte makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Resolüte is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Resolüte determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Resolüte will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
Security of Your Information
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site, by mail or by sending an email to you.
Users Outside of the United States
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
The Site and Services are not directed to children under 13 (or other age as required by local law) (“Child” or “Children”), and we do not knowingly collect Personal Information from Children. If you learn that your Child has provided us with Personal Information without your consent, you may contact us. If we learn that we have collected any Personal Information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
Redress/Compliance and Accountability
Other Rights and Important Information
New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and your choices as required by law.
The following capitalized terms shall have the meanings herein as set forth below.
“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Resolute or to which Resolute discloses Personal Information for use on its behalf.
“Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Resolüte or its subsidiaries worldwide.
“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Resolüte or Resolüte’s agents.
Terms of Service
If you would like to contact us about our privacy practices, or exercise any of your data subject rights, please send a written request to the data controller of your Personal Information or to us at privacy@Shop-Resolüte.com or Privacy Office,
Re: Privacy Compliance Officer
9 Commercial Drive, Unit D
Hampden, MA 01036
United States of America
Resolüte, A Nolan Wells Inc. Company
Nolan Wells Inc.
26 Ryan Circle
Springfield, MA 01118