Qumpus, Inc., d/b/a RIPECARAMEL (collectively referred to herein as “RIPECARAMEL”, “we”, “our”, or “us) recognizes the importance of protecting personal data we may collect from visitors and users and any other individual or entity (“Users”, “you”, or “your”) who visit our web sites or use our Engine and Marketing Services. This Privacy Policy applies to data collection by RIPECARAMEL and shall apply to your use of the website, ripecaramel.com, www.RIPECARAMEL.co.uk, and other RIPECARAMEL- related sites, applications, software, communications, capabilities and services (“Services”) accessible on or by any top-level RIPECARAMEL domain owned by us (each, a “Site” and collectively the “Sites”), but excluding services that state that they are offered under a different privacy policy.
Our Privacy Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; and (5) the choices we offer, including how to access and delete information.
Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.
If you have any questions or comments about this Privacy Policy, please submit a request to [email protected] .
When this Privacy Policy Applies
Our Privacy Policy applies to all of the services offered by RIPECARAMEL and its affiliates and services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.
Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.
Website Terms of Use
By accessing or using the Sites in any manner, you also agree to be bound by RIPECARAMEL’ Terms of Use (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.
Information We Collect
We collect information, including personal information, to provide better services to all our Users. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.
The personal information which we collect includes, but is not limited to, the following circumstances and data elements:
You may choose to provide us with personal data about yourself, including your name, billing address, shipping address, email, phone number, zip or postal code, and user name and password, by completing forms on our website, such as when you request information about our Services, register for a program, or purchase a product. In order to complete the purchase of a product, an online credit card transaction may be required. During this process, you may provide us with the first and last name of the payment card owner, credit card billing address, payment card number, payment card expiration date, card verification value (“CVV”), shipping address, phone number and email.
When using our Services, you may provide us with messages sent between those individuals you have authorized to use our Services. In some instances, you may elect to provide us with location and address information.
You may also provide us with Personal Information about yourself when you report a problem or have a question about our services.
If you enroll and participate in our loyalty program, we may collect some personal information, such as name, email address, and date of birth.
The Sites offer interactive and social features that permit you to submit content and communicate with other users. You may provide personal data to us when you post information in these interactive and social features. Please note that your postings in these areas of the Sites may be publicly accessible or accessible to other users.
Cookies and Similar Technologies
We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third-party advertising and analytics partners include Google, Klaviyo, Attentive, Facebook, Reddit, Microsoft, and Smile.io.
The technologies we use for this automatic data collection may include:
• 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 services. 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 services. For more information about our use of cookies, including details on how to opt-out of certain cookies, please see our Cookie Policy
• Web Beacons. Pages of our services or 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 us, for example, to count Users who have visited those pages or opened an e- mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.
How We Use Information We Collect
We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
1. To inform you about services available from RIPECARAMEL;
2. To authorize access to our Sites and Services;
3. To provide you with Services and Products;
4. To offer and administer programs;
5. To administer content, promotion, sweepstakes, surveys, voting polls or other Site features;
6. To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, and other offers or promotions, and to deliver pertinent emails;
7. To improve our customer service;
8. To respond to and support users regarding their use of the Sites and Services;
9. To comply with all applicable legal requirements.
10. To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our Users.
11. To enroll you in, facilitate the administration of, and coordinate offers and activities relating to our loyalty program.
We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our Company and our users.
We use information collected from cookies and other technologies, to improve your User experience and the overall quality of our services. We may use your Personal Information to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.
Our Legal Basis for Collecting Personal Information
Whenever we collect Personal Information from you, we may do so on the following legal bases:
1. Your consent to such collection and use;
2. Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services, your purchase of a product or your purchase of a product or your request for Services;
3. Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:
• Intra-organization transfers for administrative purposes;
• Product development and enhancement, where the processing enables RIPECARAMEL to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our Users, and to better understand how people interact with our Sites;
• Fraud detection and prevention;
• Enhancement of our cybersecurity, including improving the security of our network and information systems; and
• General business operations and diligence;
4. Based on our statutory duties and obligations or other circumstances as prescribed by laws and administrative regulations.
Your Failure to Provide Personal Information
Your provision of Personal Information is required in order to use certain parts of our services and our programs. If you fail to provide such Personal Information, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.
Our Retention of Your Personal Information
We determine the appropriate retention period for Personal Information on the basis of the amount, nature and sensitivity of your Personal Information processed, the potential risk of harm from unauthorized use or disclosure of your Personal Information and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
Sharing Personal Information
RIPECARAMEL may disclose your Personal Information to commercial providers for a business purpose, which includes verifying your identity when making a payment or registering access to your accounts. When we disclose Personal Information for these reasons, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.
We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of RIPECARAMEL if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
• Fulfill any purpose for which you provide it;
• Meet any applicable law, regulation, legal process or enforceable governmental request;
• Enforce applicable Terms of Use, including investigation of potential violations;
• Detect, prevent, or otherwise address fraud, security or technical issues;
• Protect against harm to the rights, property or safety of RIPECARAMEL, our Users or the public as required or permitted by law;
• For any other purpose disclosed when you provide the information; and,
• When we obtain your consent to do so.
We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
We may disclose your Personal Information in the event of a business transfer. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Information about our users is often a transferred business asset. In the event that RIPECARAMEL itself or substantially all of our assets are acquired, Personal Information about our users may be one of the transferred assets.
We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
Your Privacy Choices
You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you choose to be a guest or visitor at one of our managed properties, we aim to provide you with choices about how we use your Personal Information.
Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.
• Privacy Rights Specific to California Residents
Under the California Privacy Rights Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.
Below we further outline specific rights which California residents may have under the California Privacy Rights Act.
Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12- month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
Right to Delete Your Data. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
Right of correction. You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Privacy Rights Act.
Exercising Your Rights
If you are a California resident who chooses to exercise your rights, you can:
1. Submit a request by downloading and filling out this form and email it to [email protected]; or
2. Call 1-800-894-0242 to submit your request.
You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.
Our Response to your Request
Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.
We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.