Privacy Policy

Rhino-Rack USA, LLC understands that privacy is important for individuals. This Privacy Policy (“Policy”), as updated from time to time, sets out the practices of Rhino-Rack USA, LLC (“we”, “our”, “us” and “Rhino-Rack”) with respect to our collection, use, handling and sharing of your personal information. This Policy governs your use of our services, products, website (www.rhinorack.com), subscriptions, mobile applications, social media, online services, off-line services, in-person interactions and communications with you.

1. DATA RECEIVED OR COLLECTED

Personal information we may receive or collect from you includes:

• Contact and registration information, including your name, residential address or zip code, email address, phone and/or mobile number, login details and password, social media account information.
• Identification information, including your gender, birth year, background, nationality, marital, family and employment details, information about your hobbies and interests, signature, driver’s license and social security number, or other information which identifies you and can reasonably be associated with you.
• Financial and payment information, including your credit card details, billing information, bank account information for direct debit (if applicable).
• Details about your vehicle and roof-rack products and accessories, including vehicle make, model and year; roof-rack products, accessories and other product information (serial or part numbers); purchase information and history, such as products, price, location and dealer details, installation information and service details, and how you communicate with us and our dealers in relation to our products and services.
• Posting and uploading, including any reviews, posts, photos, videos or other content you choose to submit to us or post or upload on our website or social media.
• Device and technical information, including information about devices and browsers you use to access our website, mobile application, emails, social media accounts and advertisements, details about how you browse, use and access our website or other media. We may receive and store information about your computer, or other electronic device that you use, browser, IP address, unique identifiers for your device, browser type and language, and other related software or hardware information, or related information for that device. Certain technical information may be collected through log files and servers. Web and application servers create log files automatically as part of their setup and configuration. Information in a log file may include IP address, browser type, Internet service provider, date/time stamps, Media Access Control (MAC) address, file requested, and other usage information and statistics.
• Location information. As part of your contact information, you provide us with your zip or postal code. We may also collect location information, including your exact geolocation (unless you disable such access on your device), from devices you use while accessing our website or services. Device-based location information may be derived from GPS and nearby wireless signals. Your location within a geographic block may be approximated from the IP address assigned to your device.
• Research or survey information. If you participate in our surveys or research, we will collect any information you choose to provide to us, together with other data about your use of our products.

2. HOW INFORMATION IS RECEIVED OR COLLECTED

Your personal information may be received or collected in the following ways:

1. You provide it to us.
   This collection occurs when you register or submit your information on our website, social media, participate in a show, event, promotion or other activity, purchase our products or services, and communicate or engage with us in some other manner, and provide your personal information to us. The types of personal information that you provide include contact, registration and identification information, information about your vehicle and roof-rack products, visual, audio or electronic content.
2. We collect it using IT resources.
   This collection occurs when you access our website, emails, social media, advertisements and promotions. Information is collected automatically as you access and use our website, emails, social media and advertisements. Information that we collect includes device, IP address and technical information to identify you and log your use, purchase information and history, location information, geolocation, information recorded on our surveillance cameras if you are on or around our premises or facilities. When you visit or otherwise use our website, application, social media account, videos, adds or other technology, browse or perform a search, we use log-ins to log your visits and usage data.
   Cookies and similar technologies
   We also use cookies and similar technologies, such as pixels, ad tags and tracking technologies. A cookie is a small file of letters and numbers that we may store on your browser or your computer, if you accept our use of cookies. Cookies contain information that is transferred to your computer’s hard drive. Please read our Cookie Policy for a detailed explanation of what types of cookies we use, for what purposes and what your rights and options are. Our Cookie Policy forms part of our Privacy Policy and applies to any use of and access to our website, emails, social media, advertisements and promotions. “Do Not Track” is a signal that may be transmitted by some browsers and has been recommended as a tool for allowing Internet users to control the tracking of their online activities by using browser settings. As there is no agreement how to interpret a DNT signal, Rhino-Rack does not respond to “do not track” signals.
3. We receive it from third parties.
   We may receive or collect your personal information from third parties, such as our dealers, distributors, affiliates, service providers, advertising agencies, marketing companies and data providers, government agencies, third party social media websites and applications. We may combine and store that information on our servers with other information we may have already received or collected from you. Information that we may receive from our dealers, distributors or business counterparties include contact and identification information, information about your vehicle and roof-rack products that you may have purchased or be interested in. Service providers, advertising entities, marketing companies and data providers may provide information about the products and provide website content which you have accessed, browsed or inquired about, your preferences, product choice, your identification information, purchase history, location, device and other technical information. Governmental or quasi-governmental agencies may provide or make available, to the public, census and demographic data. Third-party social media websites, applications, or services that you use may automatically provide us with information about you to facilitate personalization unless you use the controls available on those websites, applications, or services to opt-out of such sharing. Third parties who store or post information about you may make this information publicly available, by posting it, for example, on a public forum, social network, or blog. We will store and use your personal information we receive or collect from third parties in accordance with this Privacy Policy. Rhino-Rack is not responsible for, and will assume no liability, if a third party collects, uses, or shares any information about you in breach of its own privacy policy or any applicable privacy legislation and requirements.

3. HOW WE MAY USE INFORMATION WE RECEIVE OR COLLECT

Rhino-Rack may use your information or data we receive or collect, as well as data we derive from combinations of the foregoing, for a variety of purposes, such as:

• to facilitate the creation of your account on our website and enable you to manage your registration;
• to supply, provide, maintain and improve our products, services and website/mobile application/social media and other information about us and our products;
• to process your order and payments for products you purchased from us, using your credit card, bank account or some other method of payment;
• to promote our products, services, website and social media;
• to develop or conduct a research on development of new products and services;
• to customize and personalize your experience, preferences and interests when you access our website or mobile application, advertising and other content about us and our products;
• to contact you and provide you with information that you have requested or agreed to receive or may be interested in receiving;
• to alert you to the latest developments in the industry and to notify you of new products;
• to fulfill your requests for products and services, such as functionality of existing products, launching new products, distributing electronic newsletters and enabling you to participate in surveys and public forums;
• to analyse, maintain and improve performance, effectiveness, security, and safety of our products and website;
• to communicate and manage our relationship with you, including addressing any service and administrative issues;
• to respond to your inquiries, service requests, questions on products, website, services, promotions and events we may organise;
• to manage warranty and any other claims and provide product support and service information;
• to analyse data about the use of and preferences about products and products features;
• to make use of your information consistent with the context in which the information was collected or with your consent for other internal business purposes in compliance with applicable laws and regulations.

4. HOW WE SHARE INFORMATION WE RECEIVE OR COLLECT WITH OTHERS

1. Related companies and affiliates.
   We share your information with Rhino-Rack’s related companies and affiliates, which may be located in other countries. We may share your information for the purpose of monitoring, research and development in relation to existing and new products, to promote our products and services, and for other purposes relating to products offered by Rhino-Rack.
2. Suppliers and service providers.
   Third parties who provide services to us, such as website support and hosting, data analytics, other IT services, e-commerce and payment processing services, marketing and advertising services, product research and development, may get access to your information while performing their services or we may provide that information to them to facilitate the provision of services. Rhino-Rack may share information we gather from devices you use to access our website and products with service providers, manufacturers or distributors, or advertising entities for the purposes user analytics, tracking advertising events, security and fraud detection, debugging problems with our website, and for providing you with more relevant advertisements.
3. Dealers, distributors and business counterparties.
   We may share your information with our dealers and distributors for various purposes, such as, to supply products to you, provide information about products and product services, inform you about promotions, and to provide you with warranty, recall, and service information. Our dealers and distributors are separate legal entities and have their own privacy practices. Please contact them directly if you have any questions about the privacy practices or to opt out of marketing communications from them. We work closely with vehicle manufacturers and suppliers to monitor, analyse and track the demand for roof-rack products. We may also share your information with third parties which develop rook-rack accessories or related products. We may also work with sponsors, or sponsor some events, and work with other independent businesses in relation to events, shows, promotions and contests. We may share your information with those business counterparties.
4. Email address and contact information.
   We do not sell your information. We do not provide your email address or contact information to other companies for their own marketing purposes without your permission. However, we may use your email address or other contact information to contact you about products, provide product support, send you notices about products and promotions, and to serve you with ads that are more relevant to your preferences. We may also work with data partners and advertising platforms to help increase the relevance of our ads. In doing so, we may use information representing an encrypted or hashed value derived from information we have received, such as your email address, in connection with these partners and platforms.
5. Legal and security purposes.
   We may share your information in order to (i) obtain legal advice; (ii) commence, participate in or defend legal claims and complaints; (iii) protect the safety and security of Rhino-Rack, its customer, or members of the public including acting in urgent circumstances; (iv) protect against fraud or to conduct risk management; (v) comply with the law, legal process, court order or legal and government requests; (vi) enforce our agreements, rights, and protect our property, including intellectual property; or (viI) address or assist in relation to other compelling reasons relating to legal and property rights, safety and security of Rhino-Rack and general public.
6. Information you post in a public profile or to our website.
   You should be aware that any information you share or post on our website, social media accounts, blogs, and other media in connection with us and our products may be read, collected, and used by others who access them.
7. Assignment, novation or reorganization of business.
   We may share your information with third parties in connection with any reorganization, merger, acquisition, sale, joint venture, assignment, transfer, or other disposition of all or any part of Rhino-Rack’s business, assets or stock.
8. With your consent.
   We may otherwise share your information with third parties if you consent to such sharing.
9. Sharing of deidentified, aggregated, or anonymized information.
   Rhino-Rack may share deidentified, aggregated, or anonymized information we receive or collect with third parties to analyze website and social media usage, improve the products and services, improve the serving of advertisements, or for other similar purposes. Such information will not identify you individually. If your personal information is transferred or shared with third parties as described in this policy, we will seek assurances from the recipients of such information (prior to the transfer) that they will comply with privacy laws and in a manner consistent with this Privacy Policy. However, we are not responsible and disclaim any liability in relation to privacy practices of such third parties or third parties whose products or services you access through our website, products or services. Please contact them directly to get access to their privacy policy or to resolve any issues you may have in relation to handling of your personal information by them.

5. LINKS TO THIRD PARTY WEBSITES AND PLUGINS

Our website may contain links to websites, mobile applications or services operated by third parties, and plugins from social media platforms and other third parties (“third party links”). Rhino-Rack does not re-publish, endorse, recommend or approve the third party links, has no associations with their operators, makes no representation or warranty concerning the accuracy or other characteristics of the content of the third party links or the experience you will have, and is not responsible for the privacy or other policies or privacy practices of those third parties.

6. RIGHTS TO ACCESS AND MANAGE YOUR PERSONAL DATA

You have rights and choices in relation to the information you provide and how we use and share that information. You can:

• access, review, correct and modify your personal information by contacting our Privacy Officer as shown in the “Contact Us” section below. We aim to respond to requests within 24 hours of receiving a request, but it may take up to 30 days depending on the volume of requests we receive;
• choose not to provide certain information requested. That may limit the functionality or benefits of our website or services;
• cancel or deactivate your registration with us. If you would like to request the cancellation or deactivation of your registration, you should contact us for assistance. Cancellation or deactivation of your registration does not ensure complete removal of the content or information you may have provided or posted;
• opt out of promotional, marketing or other communications from us. You may opt out of receiving newsletters, promotional and marketing emails by using the unsubscribe function in the emails you receive. You may also opt out by submitting a request to our Privacy Officer as shown in the “Contact Us” section below;
• adjust the location settings of your mobile device at any time to control whether your device communicates and shares location information, and you may have the option to adjust the permissions in the app. See your device settings for further information;
• choose to receive or stop “push notifications” on our mobile applications at any time by adjusting the settings on your mobile device, and you may have the option to adjust the permissions in the app.

7. DATA RETENTION

We retain and use your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including to offer our products and services to you, facilitate our work as a supplier of high quality roof racks and accessories and the management of our business relationships with distributors, customers and suppliers, comply with our legal or contractual requirements and obligations, resolve disputes, and enforce our agreements.

8. SECURITY

We use an appropriate combination of:

• physical measures including barriers, locks, doors and alarms and door-access technology where our lease arrangements permit;
• up-to-date computer virus prevention technology, password security and firewalls for our computer systems and websites; and
• behavioural and administrative protocols

within our means, to exclude unauthorised persons or intruders from gaining access to information.

We process your information in the United States and overseas countries. Those countries may not have the same level of protection for your personal information as the United States. By using our website and services and by providing your information, you acknowledge and understand that your information will be transferred to and processed in the United States and these other countries.

While we are taking relevant security measures to protect personal information we hold, we cannot guarantee the security of the information we collect, hold and process.

9. OUR POLICIES CONCERNING CHILDREN

Rhino-Rack does not allow for registration by, and does not knowingly collect personal information from, anyone under 13 years of age. In the event we gain actual knowledge that we have collected information from or about children under the age of 13, we will take measures to remove such information. If you believe that we might have any personal information from a child under the age of 13, please contact our Privacy Officer.

10. PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

Rights under the California Consumer Privacy Act of 2018 (CCPA).

CCPA provides for certain disclosures about your rights and personal information we collect, use, share and disclose for business purposes.

10.1 Categories of personal information

We collect the following “Categories” of “Personal Information,” as defined in CCPA:

1. Identifiers
   Examples:
   Full name, address or zip code, email address, internet protocol address, online identifier, social security number, driver’s license number, or other similar identifiers
2. Categories of personal information in California Civil Code Section 1798.80(e)
   Examples:
   Full name, physical characteristics or description, address, telephone number, driver’s license number, social security number, insurance policy number, education, employment, employment history, or financial information
3. Characteristics of protected classifications under California or Federal Law
   Examples:
   Race, nationality, origin, background, religion, age (over 40), gender, marital status, family details
4. Financial and payment information
   Examples:
   Credit card details, billing information, your contact details, address, bank account information if you wish to use a direct debit facility
5. Commercial Information
   Examples:
   Records of vehicles, roof rack products or accessories purchased, obtained, or interested in
6. Internet or Other Electronic Network Activity Information
   Examples:
   Browsing history, search history, and information regarding your interaction with an internet website, application or advertisement
7. Geolocation
   Examples:
   Exact geolocation data from your mobile or other location sharing device
8. Audio, electronic, visual, or similar information
   Examples:
   Photos, videos, service call recordings, or facility camera footage
9. Professional or employment-related information
   Examples:
   Occupation, job title, employer, professional associations or other membership information
10. Inferences drawn from personal information
    Examples:
    Information about your interests, preferences or likelihood to purchase our roof rack products and accessories

10.2 Collection practices

We use the following sources of information:

1. You or your devices. You may provide your Personal Information to us. We collect Personal Information from your devices, through your use of our website, social media, products, services and other interactions or direct communications with us. We also use cookies and similar technologies. Please access and read our Cookie Policy here.
2. Suppliers and service providers. We receive your Personal Information from the third parties who provide services to us, such as IT service providers, or advertising and marketing agencies.
3. Dealers and distributors. We receive your Personal Information from our dealers and distributors.
4. Business counterparties. We receive your Personal Information from third parties we work with to develop and make products and services available to you, and those we work with to sponsor shows, events and promotions.
5. Publicly available sources. We receive your Personal Information from publicly available sources, such as, information from government agencies, information posted on social media, public domain, website or other internet resources.
6. Consumer data resellers. Third parties may sell your Personal Information which you provided to them or they collected, to us.

10.3 Use of your Personal Information

We use your Personal Information for the following business purposes:

1. Supplying products and services. We use Personal Information to supply, maintain and improve our products, services and website. We also use it for research and development of new products, services, and website or mobile applications. For example, we may analyse the demand for specific products or features, make new products compatible with certain technology, improve products’ use and features, evaluate products’ performance, effectiveness, security, and safety.
2. Processing payments. If you purchase products directly from us by phone, or using e-commerce or other online order and payment facility, we will need your credit card and other billing information to take and process payment. Processing of payments can be facilitated by a third-party service provider.
3. Marketing and promotion. We use Personal Information for marketing and promotional purposes to suit your preferences and interests, to customize and improve promotional and advertising materials that may be of interest to you.
4. Communicating with you. We use Personal Information to communicate and interact with you. For example, we may provide you with information about our products, services, website, social media, respond to your questions or service requests, manage and improve our communications with you, contact you about upcoming shows, surveys, promotions, events, and other activities.
5. Warranty and product support. We use Personal Information to address warranty claims and facilitate or manage product service and support. For example, we may need to investigate, address and respond to warranty claims, provide product service and maintenance information and support, or provide recall information.
6. Legal reasons. We use Personal Information to deal with legal issues. For example, we may need to obtain legal advice, commence, maintain or defend legal claims or complaints, bankruptcy proceedings, comply with applicable laws and regulations, contractual requirements and court orders, respond to requests from government and legal authorities, detect, prevent and address fraud, violation of law, intellectual property infringement, security and safety issues, breach of our agreements, misuse of our products, services, or website, protect property, safety, rights, interest, welfare of Rhino-Rack, you, or public.
7. Deidentification and aggregation. We de-identify and aggregate Personal Information and use it for any lawful purpose, without identifying you.
8. Other purposes. We may use Personal Information for other purposes for which we provide specific notice when the information is collected.

10.4 Sharing your Personal Information

We share your Personal Information for the purposes identified above with the following categories of third parties:

1. Related companies and affiliates. We share Personal Information with related companies or Rhino-Rack and affiliates, which are located overseas.
2. Suppliers and service providers. We share Personal Information with third parties who provide services to us.
3. Dealers and distributors. We share Personal Information with our dealers and distributors.
4. Business counterparties. We share Personal Information with businesses we work with to develop and make certain products and services available to you, and those we work with to participate and sponsor shows, events and various promotions.
5. Third parties for legal reasons. We share Personal Information with third parties, including government entities and agencies for the legal reasons set out above.
6. Third parties for business reorganizations. We share your information with third parties in connection with any reorganization, merger, acquisition, sale, joint venture, assignment, transfer, or other disposition of all or any part of Rhino-Rack’s business, assets or stock.
7. Third parties with consent. We share Personal Information with third parties for whom you have provided your consent to share your Personal Information. This includes the content that you choose to post or share on our social media or website.

10.5 Sale of Personal Information

We do not sell your Personal Information. We share Personal Information with third parties as set out above, including when we allow third party providers to place cookies and similar technologies on our website to conduct analytics and advertising.

10.6 California residents privacy rights

California residents have the right to make certain requests about their Personal Information under CCPA. You may request to:

• Access and/or obtain copies of your Personal Information or any part of it;
• Provide you with information about: the categories of Personal Information we collect, disclose, or share about you; the categories of sources of such information; the purposes for collecting or using your Personal Information; and the categories of third parties with whom we have shared Personal Information during the past twelve months; and/or
• Delete your Personal Information wholly or partially, subject to the exceptions set out in CCPA.

You submit your request to our Privacy Officer:

• by email at privacyofficer@rhinorack.com ;
• by fax on +1 303 706 9701;
• by phone on +1 877 744 6622 (Toll Free) or +1 303 706 9700 – hours of operation [insert]; or
• by post or in person at 2450 Airport Boulevard, Unit D Aurora, Colorado 80011 – hours of operation [insert]

Please note that our response to your request may be limited as provided by CCPA. For example:

• all requests are subject to our ability to reasonably verify your identity and request in light of the Personal Information relevant to the request and the requirements in CCPA. We may ask for additional information to verify your identity and validate your request before responding to it;
• The right to have Personal Information deleted is subject to a number of exceptions set out in CCPA, such as when we need to maintain the information about the supply of roof rack products or services to you, or to comply with our legal obligations and other laws. As provided by CCPA, California residents are not to be discriminated against for exercising their rights under CCPA.

10.7 California residents rights under California Civil Code Section 1798.83 (Shine the Light Law)

Under California’s “Shine the Light Law,” California residents who provide Personal Information in obtaining roof rack products and accessories or related services for personal, family, or household use, may request information, limited to one request per California customer per each calendar year, about our disclosures of Personal Information to third parties for their direct marketing purposes.

To request this information, please send an email message to our Privacy Officer at privacyofficer@rhinorack.com with “Shine the Light Law Request” in the subject line of your email. We note that not all categories of information are covered by this law. We will only provide information which is covered by this law. 10.8 California residents rights under Cal. Bus. & Prof. Code Section 22575(b) ("Do Not Track" Browser Settings).

Like many other websites and businesses with online presence, we do not currently respond to “Do Not Track” signals if we receive them. There is no common agreement among industry participants as to what a "Do Not Track" signal means in this context.

11. FURTHER INFORMATION FOR NEVADA RESIDENTS

If you are a resident of Nevada, you may opt out or apply limits to the sale of personally identifiable information to third parties, subject to applicable law. Rhino-Rack does not sell your personal information. However, you are entitled to register your preference for limits on such sales in the future by sending an email to our Privacy Officer at privacyofficer@rhinorack.com , with the subject line, "Nevada Consumer Request". We may ask for additional information to verify your identity and validate your request before responding to it.

12. UPDATES TO THIS POLICY

If this Privacy Policy changes, the updated Policy will be posted on this website. Please check our website periodically and read the Privacy Policy, especially before you provide any personal information to us.

13. ENFORCEMENT AND GOVERNANCE

We will conduct audits of our relevant privacy practices to verify compliance with this Privacy Policy and relevant privacy legislation. We will conduct investigations to verify that assertions regarding our privacy practices are accurate.

You may inquire about an inaccuracy or make a complaint about a potential violation of your privacy by using the contact information provided below. We provide training to our employees to ensure their following our privacy practices.

Any concerns regarding our use or disclosure of personal information may be directed to our Privacy officer. We will investigate and attempt to resolve complaints regarding collection and use of your personal information in accordance with this Privacy Policy.

For complaints that cannot be resolved, Rhino-Rack will cooperate with the respective data protection authorities located in the applicable country and engage in a dispute resolution procedure required by such authorities.

We encourage you to contact us directly to resolve and privacy or data use concern and we will use our best endeavours to address those concerns to your satisfaction. 14. CONTACT US If you have any questions or require further information about our approach to privacy, our privacy practices, this Privacy Policy, or wish to request access to personal information we hold about you, or submit a complaint, please contact our Privacy Officer at: Phone: +1 303 706 9700 Email: privacyofficer@rhinorack.com Address: 2450 Airport Boulevard, Unit D Aurora, Colorado 80011 Days and Hours of operation: Or call Rhino-Rack on its general number at +1 877 744 6622 (Toll Free) during [days, hours].