Last Update Date: January 1, 2024
This Privacy Policy applies to the information that you provide to RightDecisionsRightNow.com which is operated by RAI Services Company, a subsidiary of Reynolds American Inc. (“RAI”, “we”, “our” or “us”) in connection with your interactions with us via mail, email, telephone, text message, mobile app or the Internet. The references in this Privacy Policy to “Website” refers to the website that links to this Privacy Policy and also refers to mobile apps that link to this Privacy Policy if applicable in the relevant context. By interacting with us and sharing information about yourself or others, you agree that the information you share will be handled in accordance with this Privacy Policy, as amended. By interacting with us and sharing information about yourself or others, you agree that the information you share will be handled in accordance with this Privacy Policy, as amended.
RESTRICTIONS ON ACCESS AND USE
Adult Audience Only. You must be at least 21 years of age to access this Website. By using the Website you certify that you are 21 years of age or older.
Geographic Restrictions. This Website is operated, in whole or in part, from the United States. Personal information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, or service providers elsewhere in the world. By using this Website, or transmitting information to us, regardless of where you live in the world, you consent to have any personal information you provide to us transferred to, processed, and stored in the United States or elsewhere in the world, and you authorize us to use and collect your personal information in accordance with this Privacy Policy. We will undertake reasonable steps to protect the privacy and security of personal information according to this Privacy Policy regardless of where it is processed or stored, although we cannot guarantee against illegal access to it and we disclaim liability for such illegal access.
WHY WE COLLECT
This Website is operated for the purpose of providing educators, parents, guardians, grandparents, and community leaders with tools to help persuade youth in grades 5-9 to be tobacco and nicotine free. We collect information to serve these purposes, including to administer, operate and improve this Website.
WHAT WE COLLECT
We collect information about you in many ways, including directly from you, your devices and your interactions with us, whether in person, by mail or electronically, including on this Website. We may also receive information about you from service providers that provide services for us in connection with this Website as well as from service providers to whom you have provided information.
Personal Information. As used in this Privacy Policy, “personal information” is data that can be used to uniquely identify or contact an individual. There are several ways in which you may explicitly and intentionally provide us with, and consent to our collection of, personal information, including:
Examples of Information That You May Provide to Us:
- Completing a “Contact Us” form or Webform. If you contact us via email or similar type of form, we require you to provide your name.
Examples of Information That May Be Collected Automatically:
- Location Information.The device you use to access this Website may transmit general location information (e.g., region, city and state) to us.
- Traffic Data.Whenever you visit or interact with this Website, we (as well as our service providers) may use assorted technologies that automatically or passively collect information about how it is accessed and used by you. We refer to this information as traffic data. Traffic data may include, but is not limited to, your IP address, device type used to access this Website (i.e., computer or mobile device), unique number assigned to identify such device, application version, click path taken through this Website and your use of features or applications on this Website. Technologies we use to collect traffic data, include, but are not limited to, cookies and beacons.
- Cookies.Cookies are pieces of information that a website stores on your computer. We may place temporary cookies or similar files on your computer or other devices used to access this Website to facilitate navigation, to personalize your experience while visiting this Website, and for security purposes (such as to maintain security while you browse this Website. Please refer to your browser’s help menu for more information on how to manage your cookie settings. If you disable or opt out of receiving cookies, some features and services on this Website may not work as intended and you may not have access to all of the services and features we may offer.Cookies are pieces of information that a website stores on your computer. We may place temporary cookies or similar files on your computer or other devices used to access this Website to facilitate navigation, to personalize your experience while visiting this Website, and for security purposes (such as to maintain security while you browse this Website. Please refer to your browser’s help menu for more information on how to manage your cookie settings. If you disable or opt out of receiving cookies, some features and services on this Website may not work as intended and you may not have access to all of the services and features we may offer.
- Google Analytics. One type of cookie this Website uses is Google Analytics, which we use to help analyze how users use this Website. Google Analytics will collect standard Internet log information and visitor behavior information in an anonymous form. The information collected by the cookie about your use of this Website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of this Website and to compile statistical reports on website activity for this Website. Google Analytics collects information anonymously and reports website trends back to us without identifying individual visitors. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a computer user. We will not associate any cookie data gathered from this Website with any personal information from any source unless you explicitly submit that information via a fill-in form on this Website. You can opt out of Google Analytics using your browser features. For more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page.
- Beacons.Web beacons (also known as spotlight tags, Internet tags, pixel tags and clear GIFs) are transparent images that may appear on this Website, in our emails, or elsewhere. Web beacons may collect information about your interactions with this Website and our emails, including the pages you view, the emails you open, the features you use, the links you click and other actions you take in connection with this Website or emails from us in order to deliver content that may be of the most interest to you and to improve this Website.
WHO WE MAY SHARE INFORMATION WITH
We may share your personal information with the following parties:
- Our Affiliates and Service Providers. We may share and disclose information among our businesses, including employees, agents and affiliates of our businesses. In addition, we may share your information with non-affiliated businesses that perform services for us. For example, among other things, we may use a service provider to correct technical problems and malfunctions on this Website and to help us provide, improve, protect, and promote this Website and services. When we contract with such service providers to help us conduct our business, we do not permit them to use or store your personal information for any purpose other than the work they are doing on our behalf or as required by law.
- Other Third Parties. We may also share your information with non-affiliated third-parties, including, for example: (1) if we believe that there has been a violation of our policies regarding this Website; (2) if we believe that someone may be causing injury to our rights or property, or those of anyone else; (3) to respond to judicial process or to provide information to law enforcement or other governmental agencies; (4) otherwise as required by law; or (5) in the event of a liquidation, reorganization, merger, consolidation, change of control, asset or stock acquisition/disposition or other corporate combination.
HOW WE PROTECT YOUR PRIVACY
We use reasonable precautions, including, but not limited to, technical, administrative, and physical procedures, to protect personal information from loss, misuse, or alteration. Although guaranteed security does not exist on the Internet or offline, we make commercially reasonable efforts to handle such information consistent with this Privacy Policy and applicable laws. Due to the design of the Internet and other factors outside our control, we cannot guarantee that communications between you and our servers will be free from unauthorized access by third parties. Therefore, your use of this Website, social media and other platforms and sharing of your personal information with us is at your own risk.
HOW YOU CAN MANAGE YOUR PRIVACY
Using an “unsubscribe link”. If you receive an email communication from us, you will be given the option to “unsubscribe” from receiving further email communications from us at any time.
Be sure to include any contact information that you want removed from our contact list, including physical addresses, phone numbers, and email addresses (if you use more than one email address, send your opt-out email from each of your email addresses).
We may not be able to correct or update personal information previously provided by us to third parties. Your option to unsubscribe will not preclude us from corresponding with you, by email or otherwise, regarding your existing or past business relationships with us, if any (e.g., any use of our services, or responses to requests for information you pose to us either through use of this Website or by other means), and will not preclude us from accessing and viewing your personal information in the course of maintaining and improving this Website and our services.
Do Not Track Requests & Third-Party Tracking. Unless your browser settings are configured to make your online activities and publicly available information about your online activities (such as traffic data described above) invisible to usage analytics tools, your online activities within a website are not omitted from usage analytics to the extent your browser only sends us a “do not track” message and does not otherwise screen you from tracking without any action on our part. Third-parties, other than our service providers (such as our website analytics providers), do not have authorization from us to track which websites you visited prior to and after visiting this Website. That said, we cannot control all third-party tracking and there may be some third-party tracking over time and across third-party websites that occurs without our knowledge or consent.
How You Can Protect Yourself Against Identity Theft. If you would like to learn more about protecting against identity theft, you can visit the FTC’s website for more information on how to avoid identity theft at: https://www.consumer.ftc.gov/features/feature-0014-identity-theft.
LINKS TO THIRD-PARTY WEBSITES
From time to time, this Website may provide information about or links to unaffiliated third-party websites. Those websites operate independently from us (and our affiliates) and may have their own privacy statements in place which we recommend you review if you visit any linked websites. To the extent any such third-party websites you visit are not owned and operated by us or our affiliates, RAI or our affiliates are not responsible for their content or any use of those websites. The ability to access information of third parties from this Website, or links to other websites or locations, is for your convenience and does not signify our endorsement of such third parties, their services, other websites, products, services, locations or other content.
NOTICE TO CALIFORNIA, VIRGINIA, COLORADO, UTAH, CONNECTICUT, TEXAS, AND MONTANA RESIDENTS – YOUR STATE LAW PRIVACY RIGHTS
If you are a California, Virginia, Colorado, Utah, Connecticut, Texas, or Montana resident (each, an “eligible resident”), you have certain rights, pursuant to the consumer privacy laws of your state of residence. These state law privacy rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. You can exercise these rights using the contact details below.
Your State Privacy Rights
Right to Know or Access | As an eligible resident, you have the right to request that we disclose what categories of personal information we collect, use, disclose and/or sell; the categories of sources from which the personal information is collected; the business or commercial purpose for collecting, selling, or sharing personal information; the categories of third parties to whom we disclose, share or sell information; and specific pieces of personal information we have collected about you; and you have the right to confirm if we are processing your personal information and access your personal information. To enable us to fulfill that request, we will need to verify your identity. We may ask for certain information to verify the request in accordance with applicable law. If we use a service provider for such verification, then that service provider will not retain such information provided for verification purposes. |
Right to Data Portability | As an eligible resident, you have the right obtain the personal information you request in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity without hindrance. To enable us to fulfill that request, we will need to verify your identity. We may ask for certain information to verify the request in accordance with applicable law. If we use a service provider for such verification, then that service provider will not retain such information provided for verification purposes. |
Right to Correct | As an eligible resident, you have the right to request that we correct your inaccurate personal information collected or maintained by us. To enable us to fulfill that request, we will need to verify your identity. We may ask for certain information to verify the request in accordance with applicable law. If we use a service provider for such verification, then that service provider will not retain such information provided for verification purposes. |
Right to Request Deletion | As an eligible resident, you have the right to request the deletion of your personal information collected or maintained by us. To enable us to fulfill that request, we will need to verify your identity. We may ask for certain information to verify the request in accordance with applicable law. If we use a service provider for such verification, then that service provider will not retain such information provided for verification purposes. |
Right to Non-Discrimination | As an eligible resident, you have the right not to receive discriminatory treatment by us for the exercise of any of your privacy rights. |
Right to Non-Discrimination | If you are an eligible resident and would like to submit a verifiable consumer request, you can do so by emailing info@rightdecisionsrightnow.com with the subject line “Privacy Request.” We may ask for certain information to verify a request in accordance with applicable law. As an eligible resident, you can designate an authorized agent to make a request on your behalf; such authorized agent should use the same method to exercise rights on your behalf. We may require that you provide the authorized agent written permission to submit a request on your behalf and that the authorized agent verifies their own identity directly with us. |
How To Exercise Your State Privacy Rights; Authorized Agents | As an eligible resident, you have the right not to receive discriminatory treatment by us for the exercise of any of your privacy rights. |
Contact Us for More Information | If you have questions about this Privacy Policy, including anything in this section about Your State Law Privacy Rights, please contact us via email at info@rightdecisionsrightnow.com. |
In certain circumstances, we may decline a request to exercise the rights described above. If your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request. You may appeal a denied request by contacting us.
Information We May Collect, Sources of Information, How We Use It, How We May Disclose It
In addition to the information provided in the sections above titled “WHY WE COLLECT,” “WHAT WE COLLECT,” and “WHO WE MAY SHARE YOUR INFORMATION WITH,” we provide certain information about the categories of information we collect, sources of information, how we use it, and how we may disclose it in this section.
As described further in the “WHO WE MAY SHARE INFORMATION WITH” section of the Privacy Policy, we share personal information listed below internally among the RAI group of companies and with our service providers and contractors that help us operate this Website and business. We may also share personal information with a variety of third parties. If we are subject to certain corporate transactions or reorganizations; with third parties to comply with law or to protect our rights or the rights and safety of others; or for purposes otherwise disclosed or for which you have consented.
For purposes of this Privacy Policy, when we use the term “third party” we mean entities that are not service providers or contractors providing services on our behalf and that are not entities with whom you interact with directly.
In the last 12 months, we have collected each of the categories of personal information noted in the table below and disclosed it, for a business purpose, to the categories of recipients listed below. We did not “share” any of your personal information for cross-context behavioral advertising, profiling, or targeted advertising or “sell” any of your personal information to third parties during the last 12 months.
Category of personal information | Sources of personal information | Business or commercial purpose for which it was collected |
Identifiers (such as name, email address, mailing address, and online identifiers) | Directly from you; via our service providers | For our operational purposes; performing services on behalf of the business including verifying information and providing analytic services; detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity; commercial purposes |
Categories of personal information outlined in Section 1798.80(e) (such as name, phone number, mailing address) | Directly from you; via our service providers | For our operational purposes; performing services on behalf of the business including verifying information and providing analytic services; detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity; commercial purposes |
Internet or other electronic network activity (such as browsing history, browser type and version, search history, and other information regarding a consumer’s interaction with an internet website, including screen resolution, monitor color depth, operating system, JavaScript version, connection speed, device type used to access this Website (i.e., computer or mobile device), application version, click path taken through this Website, and other publicly available information) | Directly from you; via our service providers | For our operational purposes; performing services on behalf of the business including providing analytic services; auditing compliance with relevant standards; detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity; commercial purposes |
Geolocation data | Directly from you; via our service providers | For our operational purposes; performing services on behalf of the business including providing analytic services; commercial purposes |
We do not knowingly collect any personal information from anyone under 21 years of age.
We do not collect “Sensitive Personal Information” as defined in applicable privacy laws.
If you would like to print a copy of this Privacy Policy, please select the “Print” button in your web browser.
The period for which we retain your personal information varies, depending on the type of personal information and the purpose for which it was collected. The duration is limited to time necessary to fulfill the purposes for which the information was collected, in light of any restrictions or deletions you might request, as well as our need to address our legal obligations or rights.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy without prior notice to you. We will update this page when we do so. You should check this Privacy Policy frequently on this Website to see recent changes. Use of this Website following such changes constitutes your acceptance of the revised Privacy Policy then in effect.