Privacy Policy - Restful Pump, Inc.

Effective Date: Oct, 29, 2022 This Privacy Notice (the “Notice”) of Restful Pump®, Inc. (“Restful Pump®,” “we,” “us,” and “our”) describes Restful Pump’s privacy practices in connection with personal information we collect online (e.g., through our websites and mobile apps), and offline (e.g., at our events) (collectively, the “Services”). This Privacy Notice explains the types of personal information we collect, how we may use and share the information, the privacy choices and rights that you may have with respect to our handling of personal information about you, and how you can contact us if you have any questions, requests, or concerns. Please carefully review this Privacy Notice. By using our Services, including the domain restfulpump.com (the “Website”), you acknowledge that you accept the terms of this Privacy Notice.

Personal Data

“Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is a person who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, or an online identifier. You may use many of our Services without providing any Personal Data, however in some instances we may request that you provide certain Personal Data to facilitate certain Services. In such instances we collect, use, disclose, transfer, and store Personal Data to the extent necessary for certain business purposes as detailed in this Privacy Notice.

Personal Data We Collect

When accessing or interacting with our Services, you may be asked to provide us with certain Personal Data. For example, in order to access certain portions of our Website or request information about our products, you may be asked to provide your contact information. The Personal Data we collect about you depends on the particular products and services we provide to you. We may collect and use the following Personal Data:

Contact information, such as name, institution/company and department, email address, postal address, and phone number.
Additional information you may provide to us at your discretion.

If you submit any Personal Data relating to other people, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

How We Collect Personal Information

We may collect Personal Data from various sources, including:

Information Provided By You

You provide Restful Pump® with some of the Personal Data we collect– in person, by telephone, text, email, or through our website. We collect and process Personal Data you provide us with Personal Data, such as your name and contact details, and the content, date, and time of our communications via a contact form, email, or other means

Information We Collect by Automated Means Cookies and Similar Technologies To improve your experience on our Website and/or to facilitate our efforts to market our products, we may use automatic data collection technologies or web-based automated marketing solutions to collect certain Personal Data. The information that may be collected by automated means includes:

URLs that refer users to our websites
Search terms used to reach our websites
Details about the devices that are used to access our websites (such as IP address, browser type, and operating system information)
Details about users’ interaction with our websites (such as the date, time, frequency, and length of visits, specific content and pages accessed and buttons clicked during the visits, and information provided by you, including email addresses)
The technologies we use for this automatic data collection may include:
Cookies. A cookie is a small text file that websites send to a visitor’s computer or other internet connected device to uniquely identify the visitor’s browser or to store information settings in the browser. 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 or certain aspects of our Website may not function properly. For more information on how to disable cookies, please visit your internet browser’s “help” menu or you can visit http://www.aboutcookies.org/how-to-control-cookies. Please note that not all tracking will stop even if you delete cookies.
Web Beacons. Pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single- pixel gifs) that permit us to, among other things, count visitors who have visited those pages and for other related Website statistics.

How We Use Personal Data

Under data protection law, we can only use certain Personal Data if we have an appropriate reason for doing so. We rely on various legal bases to process your Personal Data, including:

Consent. You may have consented to the use of your Personal Data, for example to send you electronic marketing communications or for the use of certain cookies. Consent can be withdrawn at any time. This will not affect the lawfulness of the processing before you withdrew your consent.
Contract. We need your Personal Data to provide you with our Services, to complete your requested transactions, and to respond to your inquiries.
Legal. We may also process your Personal Data when necessary to protect your or another individual’s vital interests. We may use your Personal Data as reasonably necessary to assess and ensure compliance with applicable laws, legal requirements, and company policies; to protect our assets or to investigate or defend against any claims of illegality or wrongdoing (including to obtain legal advice or to establish, exercise or defend legal rights); and in response to a court order or judicial or other government subpoena or warrant.
Legitimate Interest. We or a third party have a legitimate interest in using your Personal Data, such as preventing fraud or promoting our events and programs. We only rely on this legal basis when such legitimate interests are not overridden by your interests or your fundamental rights and freedoms.

We use the Personal Data we collect for the following purposes:

Providing Services, including to operate, maintain, support, and provide our Services. This may include but is not limited to:

Send you information that you request about our products
Fulfill, manage and send you information about your orders
Offer and administer promotions, sweepstakes, and other contests
Provide and manage accounts

The legal basis for this processing is our legitimate interest in operating our organization and the performance of a contract with you or to take steps at your request before entering into a contract.

Communicating with You, including to contact you for administrative purposes (e.g., to provide services and information that you request or to respond to comments and questions) or to send you marketing communications, including updates on events, programs, and other offerings, and newsletters, articles, announcements, invitations and other information about concerts, programs, classes and events, and other information relating to services or benefits offered by us that may be of interest to you. The legal basis for this processing is our legitimate interest in communications and promoting our organization with our members, patrons, and participants, and the performance of a contract or to take steps at your request before entering into a contract.
Personalization, including to customize our website and Services to you and provide you with the most relevant marketing and advertising materials. The legal basis for this processing is our legitimate interest in customizing our Services and promoting our organization with existing and former members, patrons, and participants and the performance of a contract or to take steps at your request before entering into a contract.
Analytics and Product Development, including to analyze usage trends and preferences in order to improve our Services, our communications and strategies, and to develop new products, services, and features. The legal basis for this processing is our legitimate interest in improving our Services or your consent, where applicable.
Aggregation. We may aggregate, de-identify or anonymize Personal Data and use the resulting information for statistical analysis, product and service development, improvement activities, or other purposes. The legal basis for this processing is to improve our Services and be as efficient as we can to deliver the best Services to you.
Administrative and Legal, such as to address administrative issues or to defend our legal rights and to comply with our legal obligations and internal policies as permitted by law or to protect your vital interests or the vital interests of another natural person. The legal basis for this processing is our legitimate interest in the protection and assertion of our legal rights and those of a third party and our legal and regulatory obligations.
Security. We may process your Personal Data for securing our environment and the Personal Data we process and to protect against, identify, respond to, and prevent fraudulent and illegal activity. The legal basis for this processing is to comply with our legal and regulatory obligations and our legitimate interest in ensuring the security of our environment and in minimizing fraud that could be damaging for you and us.
Consent. For other purposes where you have given consent.

How We Disclose Personal Data

We may disclose Personal Data about you under the following circumstances:

Service Providers. We may disclose your Personal Data to our contractors, service providers, and other partners (including without limitation, hosting and platform providers), who support our Services or perform services on our behalf.
Legal. We may disclose your Personal Data to comply with a legal or regulatory obligation, protect and defend our rights or property, protect the safety of our visitors and website users or the public, or to protect against legal liability. We may disclose your Personal Data in situations involving potential threats to the physical safety of any person, to investigate violations of this Privacy Notice or our Terms of Use, to respond to claims of violation of third-party rights, or to protect the rights, property, and safety of Restful Pump® and our employees, agents, customers or the members of the general public.
Sale or Transfer. We may disclose your Personal Information to third parties: (i) in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets and (ii) in connection with a merger or other acquisition or if substantially all of our assets are acquired by a third party, in which case Personal Information will be one of the transferred assets.
Aggregated Information. We may use and disclose aggregated or otherwise anonymized information for any purpose, unless we are prohibited from doing so under applicable law.

We only allow our service providers to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on service providers relating to ensure they can only use your Personal Data to provide services to us and to you. We may also share Personal Data with external auditors, e.g., in relation to security accreditations or audits of our accounts. Marketing We (or our service providers and advertising partners) may send you direct marketing communications and information about our products and services that we consider may be of interest to you. You have the right to opt out of receiving promotional communications at any time by:

Contacting us at info@restfulpump.com; or
Using the “unsubscribe” link in emails

However, if you opt out of receiving such communications, we retain the right to send you non- marketing communications (such as information about your purchase or changes to our Privacy Notice). We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or Services in the future, or if there are changes in the law, regulation, or the structure of our business. We will always treat your Personal Data with the utmost respect and never sell your Personal Data.

International Data Transfers

We may transfer, store, and process your Personal Data in countries other than the country in which you initially provided the information for the purposes described in this Privacy Notice. For example, we may transfer your Personal Data to our service providers based in the United States. If you visit our Website from outside the United States, your Personal Information will be transferred to the United States. The countries to which we transfer Personal Data may not guarantee the same level of protection for Personal Data as the one in which you reside. By using the Services, you consent to the transfer of your information to the United States. EU and EEA Residents To provide the Services, we may transfer your Personal Data outside of the country in which it was collected and where the level of protection of Personal Data may be different than in your country. Personal Data may be transferred to United States of America. If we do so, we will comply with applicable data protection laws, in particular by relying on your explicit consent. For more information about how we transfer Personal Data internationally, or to obtain a copy of the safeguards we use for such transfers, please contact us as specified below.

How We Protect Personal Data

We maintain reasonable physical, electronic, and administrative safeguards designed to help protect the Personal Information we collect from unauthorized, unlawful, or accidental access, disclosure, use, destruction, alteration, or loss. Despite these efforts, however, no organization, including Restful Pump®, can fully eliminate risks or guarantee the security of Personal Data. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of information about you at any time, and we bear no liability for uses or disclosures of Personal Data or other data arising in connection with theft of the information or other malicious actions.

Personal Data Retention

We generally retain Personal Data for as long as needed for the specific business purpose(s) for which it was collected. In some cases, we may be required to retain Personal Data for a longer period of time based on laws or regulations that apply to our business or for other necessary business purposes.

Links to Third Party Websites

We may provide links to third-party websites, or may give you access to applications, software, or products that are not operated or controlled by us (the “Third Party Services”). This Privacy Notice does not apply to the Third Party Services. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content, privacy policies, or practices of those Third Party Services. We encourage you to review and understand the privacy practices of any Third Party Services before providing any information to or through them. Your interactions with these features are governed by the privacy policy of the Third Party Service that provides the feature.

Children

Our Services are not intended for use by children under the age of 18 and we do not knowingly collect or solicit Personal Information from children under the age of 18. If you are a parent or guardian and you become aware that your child has provided Restful Pump® with their Personal Data, contact us as described below. If we learn that we have collected Personal Information from a child under the age of 18, we will delete that information as quickly as possible.

Do Not Track

Restful Pump® does not support Do Not Track at this time. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit www.donottrack.us.

Additional Information for California Residents

Restful Pump® does not share any Personal Data with third parties for their direct marketing purposes. California residents have the right to receive, once a year and free of charge, information about the categories of Personal Data we disclosed to third parties for direct marketing purposes during the previous calendar year, and information about the third parties with whom we share Personal Data for their direct marketing purposes. To make such a request, please contact us using the contact information provided in the “Contact Us” section below and provide us with your name, address, and email address. We will respond to you as soon as possible and in accordance with our legal obligations after receiving your request.

Additional Information for EU Residents

Your Rights and Choices Under the GDPR As provided under applicable law and subject to any limitations in such law, you have the following rights:

Access. You may ask us to provide you with a copy of the Personal Data we maintain about you, including a machine-readable copy of the Personal Data that you have directly provided to us, and request certain information about its processing.
Rectification. You may ask us to update and correct inaccuracies in your Personal Data. You also may ask us to complete information you believe is incomplete.
Erasure. You may ask to have your Personal Data anonymized or deleted, under certain conditions.
Restrict Processing. You may request that Restful Pump® restrict the processing of your Personal Data, under certain conditions.
Object to Processing. You may object to Restful Pump’s processing of your Personal Data, under certain conditions.
Data Portability. You may request that Restful Pump® transfer the data that we have collected to another organization, or directly to you, under certain conditions.
Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data at any time and free of charge. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdrew your consent.
Right Not to Be Subject to Automated Individual Decision-Making. You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

If you would like to exercise any of these rights, please contact us using the contact details at the end of this Notice. Please provide enough information to identify yourself, including your full name and address and any additional identity information we may reasonably request from you and let us know what right you want to exercise and the information to which your request relates. We reserve the right to verify your identity in connection with any requests regarding Personal Data to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you make a request, we will try to comply with your request as soon as reasonably practicable. Note that applicable laws contain certain exceptions and limitations to each of these rights. We may reject your request, as permitted by applicable law. Please note that we often need to retain certain data for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase or promotion). There may also be residual data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may need to retain and/or not allow you to review for legal, security or other reasons.

How to Contact the Appropriate Authority

We hope that we can resolve any query or concern you raise about our use of your Personal Data. If you are an EEA or EU resident and wish to report a complaint, or if you feel that Restful Pump® has not addressed your concern in a satisfactory manner, you have the right under the GDPR to lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place. The EU Commission has a list of supervisory authorities here: http://ec.europa.eu/justice/article-29/structure/data-protection- authorities/index_en.htm.

Additional Information for Residents of Other Jurisdictions

Other jurisdictions may have privacy laws in place that convey certain rights upon their residents. If you are a resident of one of these jurisdictions and would like to exercise your privacy rights, please contact us via the information provided in the Contact Us section below. Please provide the jurisdiction in which you reside, as well as the right(s) you wish to exercise. We may request additional information in order to verify your identity.

Changes to this Privacy Notice

We reserve the right to amend this Privacy Notice at any time. If we make changes to this Privacy Notice, we will post the revised Privacy Notice on the Website, and indicate at the top of this page the date this Privacy Notice was last revised. You may read a current, effective copy of this Privacy Notice at any time by visiting this page. We will follow applicable laws and regulations regarding notification of such changes.

Contact Us

Restful Pump® is based in Massachusetts, U.S.A. and is the data controller responsible for your Personal Data. If you have any questions, requests, or complaints regarding this Privacy Notice, or if you would like to exercise your rights with respect to your Personal Data, please contact us by emailing us at info@restfulpump.com.