Introduction

This Privacy Policy describes the types of information that Roeslein & Associates, Inc. (“Company”, “Roeslein”, “our”, “we” or “us”) may collect from you or that you may provide when you visit the website www.roeslein.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. In general, we collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do so.

This policy applies to information we collect:

  • On this Website.
  • In email, text, and other electronic messages between you and us through this Website.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
  • When you interact with us in person, for example at trade shows

This policy does not apply to information collected by:

  • Roeslein, offline or through any other means, including on any other website operated by Us or any third party (including our affiliates and subsidiaries); or
  • any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to access or use our Website. By accessing or using this Website, you agree to this Privacy Policy.

This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be your acceptance of those changes, so please check this Privacy Policy for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number or any other information the Website collects that is defined as “personal” or “personally identifiable information” under applicable law (“personal information”);
  • That is about you but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties including, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on the Website. This includes information provided at the time of registering to use our Website, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Website or our online parts store (http://parts.roeslein.com) and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
  • Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash locally shared objects and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, and not this Privacy Policy.

We also use automated devices and applications, such as Google Analytics, to evaluate the use of our websites and apps and the services we provide. We use these tools to gather information about users to help us improve our services, performance and user experiences. These analytics providers may use cookies and other technologies to perform their services, and may combine the information that they collect about you on our websites with other information that they have collected. This Policy does not cover such third parties’ use of the data.

Third party ad networks may be members of either the Network Advertising Initiative (“NAI”) or About Ads-Digital Advertising Alliance (“DAI”). If they are members and you do not want to receive targeted advertisements from these third-party ad networks, you may opt out. Information as to member companies, the practices of such third-party ad networks and your choices regarding having information used by these companies, including how to opt out, can be found at either: http://www.networkadvertising.org/optout_nonppii.asp for NAI members or http://www.aboutads.info/choices/ for DAI members. Information on how to opt out of the use of your information by DoubleClick is available at http://www.google.com/policies/technologies/ads/ and information on how to opt out of Google Analytics is available at https://tools.google.com/dlpage/gaoptout.

Opting out of one or more NAI or DAI members means that only those particular members will no longer deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our websites or other non-United websites. If your browser is configured to reject cookies when you visit one of the above referenced opt-out pages and then you erase your cookies, use a different computer or change web browsers, your NAI or DAI opt-out may no longer be active.

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies (alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you use our Website. The information they collect may be associated with your personal

information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • To provide you with marketing communications
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data/adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor of our business resulting from sale of assets or stock, merger, reorganization, or dissolution, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Roeslein about our Website users is among the assets transferred.
  • To third parties to fulfill transactions for products or services you purchase from or through us. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal requirement, including to respond to any government, court or regulatory request.
  • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Roeslein, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. We will not share your information with third parties for direct marketing purposes.
  • Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our products or services, you can opt-out by checking the relevant box located on the web form on which we collect your data/[OTHER OPT-OUT METHOD] or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes, or by sending us an email stating your request to Marketing@Roeslein.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our target-audience criteria, you can opt-out by [OPT-OUT METHOD]. For this opt-out to function, you must have your browser set to accept browser cookies.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative on its website.

Accessing and Correcting Your Information

You may send us an email at privacy@roeslein.com, or contact us by mail at the address under “Contact Information” below, to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

Data Security

Roeslein maintains physical, electronic and procedural safeguards designed to protect your information. Although we take reasonable steps to safeguard and to prevent unauthorized access to your personal information, we cannot be responsible for the acts of those who gain unauthorized access and Roeslein makes no warranty, express, implied, or otherwise, that we will prevent unauthorized access to your personal information.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We should not share your password with anyone.

In addition, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Privacy Shield Registration

Roeslein complies with the EU-U.S. Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Roeslein has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not access, use or provide any information on this Website about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at marketing@roeslein.com.

Additional Information for European Union Users

In addition to the other provisions of this Privacy Policy, the following additional information and disclosures are for European Union users of this Website:

Information We Collect About You

The type of information we collect about you depends on your particular interaction with us, and includes the following information, as applicable, in addition to information described elsewhere in this Privacy Policy:

  • Name;
  • Contact information;
  • Gender and date of birth;
  • Payment information (e.g., credit card information);
  • Government ID or redress number;
  • Purchase information;
  • User and activity data from our websites and mobile applications;
  • Survey responses; and
  • Tax identification number.

Location of Your information/Data Transfer/Notice to Non-US Persons

We may transfer, store, and process information that we collect about you, as described in this Policy, in the United States, which may not provide the same level of protection for your personal information as your home country. In addition, we may further transfer your information outside the United States for the purposes described in this Policy. By submitting any personal information or by using the Website and without limitation to any other rights or obligations we have, you consent to such transfer to, and processing in, the United States and these other countries, and acknowledge that your information may be subject to access by law enforcement and other government entities, including courts and tribunals, in accordance with laws applicable in those jurisdictions.

Where personal information that we collect is transferred to and processed in the United States or anywhere else outside the European Economic Area (“EEA”) for the purposes described in this Policy, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA, including entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU – US Privacy Shield. You may have a right to details of the mechanisms under which your data is transferred outside the EEA.

Storing Data

We retain personal information for as long as necessary to fulfill the transactions you have requested or other purposes to which you have consented, or for other necessary purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Because these factors vary for different types of personal data, actual retention periods may vary. The criteria we use to determine the appropriate retention periods include:

  • How long is the personal data needed to perform the function or fulfill the purpose for which it is relevant? This is the baseline for most data retention periods.
  • Do users expect that we will retain the personal data until they affirmatively remove it? For example, if a user is able to directly access, edit or remove the personal data at any time, we may maintain the data until the user affirmatively removes it.
  • Is the personal data of a sensitive type? If so, a shortened data retention period will generally apply.
  • Has the user provided consent for a longer retention period? If so, we will retain the data in accordance with the user’s consent.
  • Are we subject to a legal, contractual or similar obligation to retain the personal data? If so, we will retain the data in accordance with our obligations.

Choices, Access, and Correction of Information

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. These rights may include the right to:

  • Access personal information
  • Rectify / erase personal information
  • Restrict the processing of your personal information
  • Transfer your personal information
  • Object to the processing of personal information
  • Object to how we use your personal information for direct marketing purposes
  • Obtain a copy of personal information safeguards used for transfers outside your jurisdiction
  • Lodge a complaint with your local supervisory authority You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make reasonable efforts to honor your request promptly or inform you if we require further information in order to fulfil your request.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. We may also, but are not required to, post a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date the Privacy Policy was “last revised” is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for visiting our Website and reviewing this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Privacy@roeslein.com

or by writing us at :

Roeslein & Associates, Inc. 9200 Watson Road St. Louis, MO 63126

Attention: Data Compliance Manager

Please reference this Privacy Policy in those communications.

 

Roeslein & Associates, Inc. Statement on Modern Slavery and Human Trafficking

This statement comprises the slavery and human trafficking statement of Roeslein & Associates, Inc. in accordance with Section 54, Part 6 of the United Kingdom’s Modern Slavery Act 2015. Roeslein is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Roeslein expects its vendors and suppliers to operate with the high principles and in compliance with employment laws and regulations around the globe, including law regarding equal opportunity, child labor, freedom of association, forced or compulsory labor, and workplace health and safety laws. Roeslein does not tolerate noncompliance with these laws and regulations, and the company will not support or engage in dealings with those whom it believes to be in material violation of any such laws and regulations.

With respect to human trafficking and slavery, Roeslein has not verified product supply chain practices, audit supplier compliance, require supplier certification, maintain separate accountability standards, or provide training for its management and employees, but does provide general training with respect to the company’s standard policies and practices.  Roeslein is unaware of any parts of its business or supply chain that present an unreasonable risk of slavery or human trafficking taking place.  In the coming year, Roeslein will take reasonable steps to investigate any complaints it receives of alleged human trafficking and modern slavery within the company or within its supply chain.  No such complaints have been received up to the date of this statement.

This statement has been approved by Roeslein’s Board of Directors and will be reviewed and published annually. This statement is for the financial year ended December 31, 2018.