The Types and Categories of Personal Information We Collect
We may collect personal information under a broad range of circumstances. Generally, we collect the following types of information directly from you:
● Identity data, such as your name, title, company/organization name, e-mail address, telephone and fax numbers and physical address (including street, city, state, postal code, and/or country).
● Registration data, such as information provided by you when you register for an account to use our Site, including usernames and passwords.
● Job Applicant data, such as contact information (including name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae (“CV”), resume, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; information related to your background, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, or qualifications; information related to previous applications to Routine or previous employment history with Routine; and, potentially sensitive information including information about your race, ethnicity, national origin, health (e.g., medical condition), and data about your criminal convictions and offenses.
● Business contact data, such as information related to other employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we may conduct, or possibly conduct, business activities.
● Marketing and communications data, including your marketing preferences and your subscriptions to our publications.
● Transaction data, including orders for our products and services and details of payments to and from you, including purchase history and limited payment card information.
● Your feedback, including feedback from you about our Site as well as our products and services generally, which may include data gathered from any Routine surveys in which you participate or reviews submitted by you.
Internet-Related Information We Collect
We collect information from visitors to our Site, including the following general data: the referring URL; your demographic information;, your Internet Protocol (IP) address; which browser you used to come to the Site; the country, state or province from which you are located; and the pages of our Site that you viewed during your visit and any search terms entered on our Site. Generally, we collect this data for the purposes of system administration, to gather broad demographic information, and to monitor the level of activity on our Site. We track visitors’ traffic patterns throughout their online sessions, including pages or specific URLs a visitor views while using the Site. We use your information to diagnose problems with our servers and software and to administer our Site.
Information Collected From and About Third Parties
How We Use your Information
We may use personal information for several business and administrative purposes, or to further our legal or other business interests. Generally, we use personal information for the following reasons:
● Services and transactions. We may use your personal information to deliver services to you or carry out transactions you have requested, including, but not limited to, providing information on Routine products or services you have purchased or otherwise use, processing product orders, handling warranty claims, answering customer service requests, and facilitating the use of our Site.
● Improving our Business. We may use your personal information to perform business analyses or for other purposes that help us to develop and improve the quality of our business, our Site, products and services (including new products and services), for example, by customizing our Site to your particular preferences or interests. We may use your personal information to conduct research and analysis to help us analyze your purchasing preferences, identify the products and services that best meet your requirements and measure the effectiveness of the advertising we serve you. Where permitted by law, we may combine the information that we collect via our Site with other information we hold about you (such as information about your use of our products and services) in order to offer you an improved and consistent customer experience when interacting with us or for other purposes set forth in this Privacy Statement.
● Marketing. In accordance with applicable laws and regulations, we may use your personal information to inform you of products or services which may be of interest to you, and to otherwise communicate with you about offerings, events and news, surveys, special offers, and related topics. You are able to opt-out from marketing communications sent via e-mail at any time, free of charge by using the “unsubscribe” link in any e-mail marketing materials you receive from us.
● Job Applicants. We use information submitted as part of a job application or inquiry to Routine for the following purposes: to identify and evaluate job applicants, including assessing skills, qualifications, and interests; to verify your information and completing employment, background and reference checks, which may be subject to your consent where required by applicable law; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements, including, but not limited to, requirements mandating that we conduct criminal record, employment eligibility, or other background checks; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and, to protect the rights, interests, and property of Routine, other job applicants, employees, or the public, as required, or permitted, by law.
● Enforcement and Protecting our Business. We may use the personal information we collect in order to detect, prevent and respond to fraud, intellectual property infringement, violations of our terms and conditions, violations of law or other misuse of our Site, products, or facilities. We may use your personal information to administer and protect our business and our Site, including troubleshooting, system maintenance, support, reporting and hosting of data. We may use your personal information to promote, defend or protect our legal, regulatory, and business interests.
We may share your personal information with selected third parties in accordance with applicable law, including as set out below.
● Service Providers. We may share your personal information with companies with whom we have contracted to provide services on our behalf, such as hosting websites, conducting surveys, processing transactions, analyzing our Site and performing analyses to improve the quality of our business, Site, products and services. We may also disclose your Personal Information to our designated agents, or third-party service providers, who require such information to assist us with administering our employment application and recruitment process, including, but not limited to, obtaining employment verification and background checks. Routine currently uses Shopify and Cart Hook as our e-commerce platforms.
● Distributors and Business Partners. We may share your personal information with third parties that distribute our products and other trusted business partners for purposes that include allowing those third parties to send marketing communications to you. Such sharing of personal information for marketing purposes will be performed in accordance with applicable laws and regulations.
● Business Restructuring. Circumstances may arise where for strategic or other business reasons Routine decides to sell, buy, divest, merge or otherwise reorganize businesses in some countries. We may disclose information we maintain about you to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, divestiture or sale of all or a portion of Routine’s assets.
● Disclosure for Other Reasons. We may disclose personal information if required or authorized to do so by law or in the good-faith belief that such action is necessary to comply with legal requirements or with legal process served on us, to protect and defend our rights or property or, in urgent circumstances, to protect the personal safety of any individual. We may share your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, and business interests. We may also disclose your information upon your express consent.
In the event that you facilitate a transaction with Routine, or request information from, or otherwise engage with us, and such activities requires Routine to share your personal information with a service provider or other third party, you hereby direct Routine to intentionally disclose your personal information to the service provider or third party as described herein provided the service provider or third party does not, in its reasonable judgment, sell the personal information, unless that disclosure would be consistent with the law.
Links to Other Websites
Data Retention and Localization
We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. However, no information system can be fully secure, so we cannot guarantee the absolute security of your personal information. Moreover, we are not responsible for the security of information you transmit to the Site over networks that we do not control, including the Internet and wireless networks, and you provide us with any information and data at your own risk. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a user ID and password to access the Site, you are responsible for keeping those log-on credentials confidential and not revealing them to others. You must contact us immediately if you have to reason to believe that your user ID or password to our Site have been compromised.
No Data Collected from Children
Our Site is not directed at nor intended for use by children. As a result, we will not knowingly collect information from children under sixteen (16) years of age with or without consent from their parents or guardians. If you are under the age of sixteen you are prohibited from using our Site or with providing us with your personal information, unless you can demonstrate affirmative authorization from your parent or legal guardian to do so.
Cookies and Web Analytics
We use different analytic tools which serve the purpose of measuring, analyzing and optimizing our marketing and provide you with customized advertisements that could be of particular interest to you. In particular, we use the following tools and programs:
● Google Analytics and Google Tag Manger. To see how you can opt-out of certain Google features and to better understand Google privacy practices, visit: Google Analytics Opt Out Link
● The LinkedIn Insight Tag. To see how you can opt-out of certain LinkedIn features, visit LinkedIn Opt Out Link.
You can find more information about cookies, behavioral advertising and online privacy at www.allaboutcookies.org.
Your Rights and Responsibilities
You are permitted, and hereby agree, to only provide personal information to Routine if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon anyone’s data privacy rights or privileges. If you provide Routine with any personal information about a third party, you expressly represent that you have the full right and authority to submit the information to Routine.
You may have certain rights under applicable data protection laws with respect to personal information about you that is collected through the Site or when you contact or otherwise engage with us. To exercise any of these data privacy rights, please contact us, or have your authorized agent contact us, in accordance with the “Contact Us” section listed below. In the event you submit, or your authorized agent submits on your behalf, a data request, you (and your authorized agent) hereby acknowledge and agree, under penalty of perjury, that you are (or the authorized agent of) the consumer whose personal information is the subject of the request. We will respond to any data requests within the timeframes required by law, and we may charge a fee to facilitate your request, where permitted by law.
Marketing. You have the right to opt-out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages, will give you an option of not receiving such communications from us in the future. California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties with whom we have reason to believe use such information for their own direct marketing purposes.
California Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents may have additional data privacy rights, such as the right to be notified about what personal information is collected about you, and our intended use and purpose for collecting your personal information. California residents have the right to know and access personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months, including the categories of personal information we have collected, used, disclosed, or sold about you; the categories of sources from which the personal information is collected; and, the business or commercial purpose for which your personal information was collected, used, disclosed, or sold; the categories of third parties with whom we have shared your personal information. California residents have the right to request Routine transfer, to the extent feasible, personal information in certain forms and formats. California residents have the right to request that we (and any applicable service provider) delete/erase your personal information under certain circumstances.
California residents have the right to opt-out of the sale of their personal information. Routine does not sell your personal information to third parties for profit. However, we do use third party website analytical tools and features, and marketing partners, and such relationships may involve the disclosure of your personal information for “valuable consideration” as set forth in the CCPA. Our Site is not directed and should not be used by minors under the age of sixteen (16) and therefore Routine does not knowingly sell the personal information of minors under sixteen (16) years of age without affirmative authorization.
California residents have the right not to be subject to discrimination for asserting their rights under the CCPA. If you make, or an authorized agent on your behalf makes, any request related to your personal information under the CCPA, Routine will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required under the law before addressing your request. Routine may require you to match at least two or three pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces, or categories of, personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein.
Do Not Track. Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
Persons with Disabilities. Routine strives to ensure that every person has access to information related to our products and services, including this Privacy Statement. Please contact us if you would like this Privacy Statement provided in an alternative format and we will seek to meet your needs
Changes to the Policy
This Policy is effective as of May 1, 2020.