Updated November 1, 2020.
RCGD Global LLC (“RCGD,” “we,” “our,” or “us”) operates the website https://rcgdglobal.com (the “Site”) and also provides the RCGD App (the “App”), which is a community focused mobile app that brings the topic of sustainable clothing and design to the hands of users around the world. The Site and the App are hubs for the services we provide (the “Services”) including information about key sustainable fashion topics, such as intersectional environmentalism, social justice, circular and regenerative design, ethical design and much more. The Site and App are also portals to eco-culture news and exclusive behind-the-scenes RCGD campaign activities. The Site and App also provide a dynamic platform for you to connect with a global community dedicated to promoting and discussing sustainability.
- Who we are;
- Personal information we collect;
- How we use personal information;
- How and when personal information is shared with other parties;
- Notifications and communications from us;
- Security of personal information;
- Rights of EEA residents under the GDPR;
- Contacting us and contacting supervisory authorities if you have a complaint;
- International data transfers;
- Rights of California residents; and
Residents of the European Economic Area (“EEA”), which includes the member states of the European Union (“EU”), should consult the sections of this policy relating to the “EEA Residents” and “International Data Transfers” describing transfer of your personal information out of the EEA for provisions that may apply to them.
California residents should consult the section titled “Your California Privacy Rights” for rights that apply to them.
Who We Are
Personal Information That We Collect
We collect Personal Information about you when you visit the Site and use the App and request more information about us. “Personal Information” is information that may be used to directly or indirectly identify an individual (which in some cases, may include certain device information). Personal Information may include (a) names, aliases, postal addresses, unique personal identifiers, online identifiers, Internet Protocol (IP) addresses, email addresses, phone numbers, geographical information, or other similar identifiers; (b) your image; or (c) Internet or other electronic network activity information obtained through your use of the App or Site and cookies including the type of device you use, the operating system used, location tracking information and mobile analytics to understand how users use our system. We may combine the Personal Information that we obtain about individuals from more than one source.
The majority of such Personal Information is collected when you use the App or register with the Site to join our mailing list or otherwise provide us with your contact information or participate in certain activities and Services provided on our Site or through the App.
We rely on a combination of legal bases to collect, use, process and share your Personal Information, including express consent, legitimate interests and contract performance.
In general, the type of Personal Information we collect includes, but is not limited to:
- Personal Information to keep in touch with you regarding features or matters of interest, including our Services or to participate in certain activities on our Site of App;
- Un-identifiable and aggregated Personal Information pertaining to your Site visits or use of the App that help us maintain the appropriate features, functionality and user experience
We and our partners may use that data to maintain regular communication with you as may be necessary to inform you of offers, updates and other information regarding us.
If you choose not to provide this Personal Information to us, we may not be able to provide you with the Services through the Site or App.
How We Use Personal Information
We use your Personal Information to: (i) provide our Services to you through the Site or App; (ii) verify your identity; (iii) allow you to use our chat feature; (iv) with your consent to add you to our mailing list and send you information about products and Services that may be of interest to you; (v) provide answers to your inquiries or questions; and (vi) for business related purposes.
Non-Identifiable Data and Aggregated Personal Information
We or our service providers, including Google Analytics, may also collect web surfing data related to your use of the Site. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Site. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any users as individuals.
Web surfing data and similar information may be aggregated for administrative purposes. We may, for example, use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies, and other marketing activities. We also use it to help optimize the Site based on the needs of our users.
How and When Your Information Is Shared With Other Parties
We will only share personal information with our group companies and our subcontractors who provide us with services, which include:
- Third party logistics and payment plug-ins to implement our web commerce and e-shops, including WooCommerce and Paypal.
We do not sell, trade or license Personal Information about you with any third parties for marketing purposes. We do not retain your payment card information.
We may share your Personal Information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your Personal Information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your Personal Information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the App, Site or our Services, or to protect the rights, property or personal safety of us, our users, issuers, or others.
We will not share your Personal Information if such sharing is prohibited by applicable privacy and data protection law, including, without limitation, the EEA’s General Data Protection Regulation (GDPR) and the California Consumer Protection Act (CCPA).
Notifications and Communications from Our Site
Communications Regarding Our Services
We will send you email notifications and free newsletters from time to time with offers, suggestions and other information. Some notifications are communications relating to us and our Services. You may “opt-out” from receiving such communications by following the “Unsubscribe” instructions provided in the email.
Legal or Security Communications
Deleting Your Information
Subject to your rights under applicable law in your jurisdiction, if you want us to delete your Personal Information and your account, please contact us at firstname.lastname@example.org with your request. We will take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law. You may not delete information relating to our communications relating to the specific Services that we are providing for you if you wish to continue receiving such Services. Deletion of your Personal Information is subject to our obligations as set forth in the section relating to Personal Information Retention.
Personal Information Retention
Links to Other Websites
Privacy in Submitted Materials
If you submit any materials to us, either directly or through a social media platform, such as Instagram, such materials, including photos or comments, may be displayed on the Site or App, including photos of yourself or other individuals. We may also display your first name in connection with the first initial of your last name in connection with comments submitted by you. By submitting such materials, you forego any privacy rights in such materials. Please consult the Terms of Service for other conditions relating to the submission of materials to us directly or through social media sites.
We take commercially reasonable steps to protect our customers’ Personal Information against unauthorized access, disclosure or loss. We limit access to your Personal Information to those who have a genuine need to know and who are subject to a duty of confidentiality. However, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, while we strive to protect user information we cannot ensure or warrant the security of any information you transmit to us or from the Site or App. You engage in such transmissions at your own risk.
If there is a data security breach of your Personal Information we will notify you and regulator(s) as required by the law of the applicable jurisdiction(s).
If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at email@example.com.
Children Under 13
Our Site and App are restricted to the use of individuals over the age of 13. We therefore will take measures to verify the age of our users. No portions of the Site or App are directed to children under the age of 13. Consequently, we do not knowingly collect personal identifying information from any person we know is a child under the age of 13. If we learn that we have collected personal information from a child under age 13 we will delete that information as quickly as possible. If you are a parent or guardian of a child under 13 years of age and you believe your child has provided us with Personal Information, please contact us at firstname.lastname@example.org .
From May 25, 2018, all processing of Personal Information of EEA Residents is performed by us in accordance with the General Data Protection Regulation (2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of Personal Information and on the free movement of such data (“GDPR”).
Your Rights Under the GDPR
Under the GDPR you have a number of important rights. In summary, those include rights to:
- Opt-out/Object to Processing.
You have the following opt-out rights/rights to object to processing your Personal Information (also referred to herein as “data” or “personal data”) which are set out in more detail below:
- To object to processing on the basis of our contract with you and or a legitimate interest;
- To withdraw consent;
- The right of erasure; and
- The right to restriction of processing.
- Our contact details for exercising your opt-out rights/rights to object to processing.
You can exercise your opt-out rights to object to processing as follows:
- In the case of special category data, by emailing us at email@example.com directed to “Data Protection Officer”
- In any case by emailing us at firstname.lastname@example.org or writing to us at RCGD, 888 Seventh Avenue, 4th Floor, New York, N.Y. 10106, USA attention “Data Protection Officer.
- Your Right to Object to Marketing.
You have the right to object at any time to processing of personal data concerning you for the purpose of marketing. This includes the right to object to processing which amounts to profiling and which is related to direct marketing. You can object to this kind of processing by emailing us at email@example.com or writing to us at RCGD, 888 Seventh Avenue, 4th Floor, New York, N.Y. 10106, USA attention “Data Protection Officer.
- Your Right to Object to Processing on the Basis of a Legitimate Interest.
If we are processing your data, including if we are carrying out profiling in respect of it, on the basis of your legitimate interest, you have the right to object at any time on grounds relating to your particular situation.
If you object, we will cease to process the data unless we have compelling legitimate grounds to continue to do so or need to continue to process the data for the establishment, exercise or defense of legal claims. You can object to this kind of processing by using the contact details above.
- Your Right to Withdraw Consent.
If you have given us consent to use your personal data, you have the right to withdraw that consent at any time. You can withdraw consent by using the contact details above.
- Your Right of Erasure.
You have the right to require us to erase your personal data without undue delay where:
- The data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- You have withdrawn your consent on which the processing is based and there is no longer any legal ground for the processing;
- You exercise your right to object to the processing when that processing is based on legitimate grounds or you exercise your right not to be subject to a decision based solely on automated processing (these rights are explained elsewhere in this policy);
- The personal data have been unlawfully processed (of course we have no intention of carrying out any unlawful processing and do our utmost to avoid any unintentionally unlawful processing); or
- The Personal Information have to be erased for compliance with a legal obligation to which we are subject.
You can exercise this right by using the contact details above.
- Your Right to Restriction of Processing.
You have the right in certain circumstances to require us to restrict processing of your data. The right applies:
- During a period to enable us to verify data which you have said is inaccurate;
- Where the processing is unlawful and you oppose the erasure of the personal data and request restriction of its use instead (of course we have no intention of carrying out any unlawful processing and do our utmost to avoid any unintentionally unlawful processing);
- We no longer need the data for the processing, but you need the data for the establishment, exercise or defence of legal claims; and
- You have objected to processing based on a legitimate interest for a period to enable us to verify whether our legitimate interests override yours.
If you exercise that right, processing of your personal data will be limited to:
- Processing to which you have consented;
- Processing for the establishment, exercise or defence of legal claims, the protection of the rights of others or for reasons of important public interest.
You can exercise this right by using the contact details above.
- Your right to fair processing of information.
You have a right to fair processing of information and transparency over how we use your Personal Information.
- Your right to access Your Personal Information.
You have a right to access your Personal Information. You can exercise this right by using the contact details above. Please provide enough information to identify yourself correctly.
- Your Right to Require Us to Correct Any Mistakes.
You have a right to require us to correct any mistakes in your Personal Information that we hold. You can request us to rectify and correct any personal data that we are processing about you by using the contact details above. We will update your personal details and keep your data accurate.
Please note that some of the above rights apply in specific circumstances and are qualified by exemptions in data protection legislation. We will advise you if we are relying on any such exemptions when we respond to you.
For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
How To Complain
We hope that we can resolve any query or concern you raise about our use of your Personal Information.
The GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the United Kingdom is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone 0303 123 1113.
Our ICO registration number is ZA 799384.
International Data Transfers
To provide our services, we may transfer the Personal Information we collect to countries outside of the EEA which do not provide an adequate level of data protection similar to that which applies in the EEA in the country in which you live and which are not recognised by the European Commission as providing the same level of data protection. We only transfer personal information to these countries when it is necessary for the services, we provide you.
Transfers of data are subject to safeguards that assure the protection of your personal information such as European Commission approved standard contractual clauses.
If you would like further information please contact us, or our Data Protection Officer please follow the instructions provided in the section of this policy relating to your rights under the GDPR.
Your California Privacy Rights
The following section pertains to the rights of individuals or households in California (“California consumers”).
- Civil Code Section 1798.83
Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer’s Personal Information with third parties for direct marketing purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their Personal Information disclosed to third parties for their direct marketing purposes.
- The California Consumer Privacy Act (“CCPA”)
After January 1, 2020, the CCPA (California Civil Code Section 1798.100 et seq.) will provide California consumers with additional rights regarding Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The categories of Personal Information we collect are generally described above but differ for individual consumers depending on the Services used by such consumers.
Under the CCPA, qualifying California consumers may have the following rights:
- Right to Know and Right to Delete.
A California consumer has the right to request that we disclose what Personal Information we collect, use, disclose and sell. A California consumer also has the right to submit requests to delete Personal Information.
When we receive a request to know or delete from a California consumer, we will confirm receipt of the request within 10 days and provide information about how we will process the request, including our verification process. We will respond to such requests within 45 days.
- Right for Disclosure of Personal Information.
A California consumer may also submit requests that we disclose specific types or categories of Personal Information that we collect.
Under certain circumstances, we will not provide such information, including where the disclosure creates a substantial, articulable and unreasonable risk to the security of that Personal Information, customers’ accounts with us, or the security of our systems or networks. We also will not disclose California consumers’ social security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medical identification numbers, or account passwords and security questions and answers.
- Submitting Requests
If you are a California consumer and would like to make any requests under the CCPA, please direct them as follows:
888 Seventh Avenue, 4th Floor
New York, N.Y. 10106
United States of America
- Verifying Requests
If we receive any request we will use a two-step process for online requests where the California consumer must first, clearly submit the request and then second, separately confirm the request. We will use other appropriate measures to verify requests received by mail or telephone.
In submitting a request, a California consumer must provide sufficient information to identify the consumer, such as name, email address, home or work address, or other such information that is on record with us so that we can match such information to the Personal Information that we maintain. Do not provide social security numbers, driver’s license numbers, account numbers, credit or debit card numbers, medical information or health information with requests. If requests are unclear or submitted through means other than as outlined above, we will provide the California consumer with specific directions on how to submit the request or remedy any deficiencies. If we cannot verify the identity of the requestor, we may deny the request.
- California Do Not Track Disclosures
Although some browsers currently offer a “do not track (‘DNT’) option,” no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers’ DNT signals.
Your Rights and Obligations
We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided to us by contacting us at firstname.lastname@example.org. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person.
If you are a resident of the EEA and wish to access or correct the Personal Information that we have about you or have any questions relating to the processing of your Personal Information, please contact us at email@example.com with the subject line “GDPR Data.”
If you use the Site or App, you are responsible for maintaining the confidentiality of your account and for restricting access to your computer or device, and you agree to accept responsibility for all activities that occur under your account.
1. PURPOSE OF THIS NOTICE
This privacy notice explains our approach to any personal information that you might supply to us (or that might be collected from you) in connection with your use of the Site and sets out your rights in respect of our processing of your personal information. This privacy notice will inform you how you can verify which of your personal information is collected by us through the Site and how you can request that we delete, update or transfer it. The notice only applies to the use of personal information collected by us from your use of the Site or during your communications with us. It does not apply to personal information collected during your communications with third parties.
2. WHO ARE WE AND WHAT DO WE DO?
The Site is operated by RCGD Global LLC (“we” “us” or “our”) whose principal activities include communications and sustainability consultancy. RCGD Global LLC is the data controller responsible for your personal information. RCGD Global LLC is registered in the State of California, with the registered office of 16027 Ventura Boulevard, Encino, California, 91436, USA.
3. HOW TO CONTACT US?
If you have any questions about this privacy notice or want to exercise your rights, please contact us by sending an e-mail to The Data Protection Officer at firstname.lastname@example.org or contact us viaThe Data Protection Officer, RCGD Global LLC, 16027 Ventura Boulevard, Encino, California, 91436, USA.
4. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
Personal information is collected from you in the following ways:
Information you voluntarily provide to us – we collect and maintain personal information that you voluntarily submit to us during your use of the Site (e.g. when registering with us or when you correspond with us) or if you sign up with us at an offline event. In particular we collect:
Other information that you provide to us (which may include information provided in any questions, comments or feedback you leave on the site).
IP address of device(s) used
Operating system and device type
Access times and dates
Referring website addresses
Information we collect from third parties.
We may also combine personal information that we collect through your use of the Site with personal information that you have provided to third parties and in respect of which you have given the third party permission to share with us.
5. HOW DO WE USE YOUR PERSONAL INFORMATION?
Our primary goal in collecting personal information from you is to:
(i) verify your identity,
(ii) help us improve the Site, improve our campaigns and develop new campaigns and areas of interest,
(iii) carry out requests made by you on the Site,
(iv) investigate or settle inquiries or disputes,
(v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator,
(vi) enforce our agreements with you such as our website terms and conditions of use,
(vii) protect the rights, property or safety of us or third parties, including other users of the Site,
(viii) provide support and security for the Site and the Functionality, and
(ix) use such information as otherwise required or permitted by law.
We will obtain your explicit consent to use your personal information for the provision of Site and the Functionality. It is also in our legitimate business interests to respond to any requests you make to us or use the information you provide to us in your feedback in order to improve our products and services.
If you have consented to us doing so we will add you to our mailing list for purposes of campaign updates, promotional and marketing messages and other communications. These mailing lists are used to provide you with further information about our work, companies we support and relevant news if you want it.
We may share your personal information collected on the Site with third parties as appropriate to
(i) carry out the activity or request made by you on the Site,
(ii) comply with any applicable law, court order, other judicial process, or the requirements of a regulator,
(iii) enforce our agreements with you,
(iv) protect the rights, property or safety of us or third parties, including other users of the Sites,
(v) perform investigative security analysis on the Site, or
(vi) as otherwise required or permitted by law.
The types of third party we share your personal information with are platform providers which allow us to deliver the Functionality on the Site and to host and store your personal data. We rely on our website development partner to develop the Site and deliver the Functionality. Our website development partner acts as data processor in relation to the collection and processing of your personal data and will only process such personal data as directed by us in accordance with data protection law.
We may also share your personal information with professional advisers or regulatory authorities:
(i) to enable them to process your personal information on our behalf in a manner consistent with this privacy notice;
(ii) to comply with our legal obligations;
(iii) to enforce our legal rights; or
(iv) protect rights of third parties.
Your personal information may also be shared with prospective buyers if we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
Any other purposes for which we wish to use your personal information will be notified to you either by updating our privacy notice or otherwise from time to time including the legal basis of such use.
6. HOW DO WE OBTAIN YOUR CONSENT?
Where our use of your personal information requires your consent, you can provide such consent at the time we collect your personal information following the instructions provided; or by informing us by e-mail, post or phone using the contact details set out in this privacy notice.
Our Site uses certain cookies, pixels, beacons, log files and other technologies of which you should be aware.
8. THIRD PARTY LINKS AND SERVICES
It is likely that the Site will contain links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this privacy notice no longer applies. This privacy notice applies solely to personal information collected by us through our Site and Functionality and does not apply to these third party websites and third party service providers.
9. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We do not keep your personal information for any specific period but we will not keep it for longer than is necessary for our purposes. In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations. If your information is only useful for a short period e.g. for specific campaigns we will delete it.
10. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Site.
11. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?
You have the following rights in relation to the personal information we hold about you:
Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to erasure
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to data portability
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, standardised and machine-readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, please contact email@example.com.
Your right to object
You can ask us to stop processing your personal information, and we will do so if we’re relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing.
Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
12. CHANGES TO THIS PRIVACY NOTICE
We may make changes to this privacy notice from time to time. To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes.
WHAT ARE COOKIES AND WHAT DO THEY DO?
A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, a computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Information gathered through cookies may include the date and time of the visits made to a website, the pages viewed and the time spent at a website.
We use “analytics” cookies which, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people visiting our website and which parts of our website are most popular. This helps us gather feedback so that we can improve our Website and better serve our users. We do not generally store any personal information that you provide to us in a cookie.
- Social Media
Most of our cookies expire within a few days, although some may persist for longer periods of time.