ROR Partners, LLC Privacy Policy 

Last Modified:  October 12, 2023 

  1. Introduction – Overview and Scope of Privacy Policy.

    This Privacy Policy applies to information that ROR Partners, LLC and its subsidiaries and affiliates (collectively, “ROR”, “we”, “our”, or “us”) processes or otherwise uses in connection with our provision of marketing, advertising, technology, data and/or analytics services (“Services”) to our direct clients and clients of our business partners (each a “Client”).

    This Privacy Policy also explains the efforts we take to safeguard your information and also indicates how you may contact us regarding our data privacy practices.  The terms “you” or “your”, as used in this Privacy Policy, refer to individuals whose personal data may be processed or otherwise used in connection with our Services.

    For clarity, this Privacy Policy only applies to ROR’s processing or use of data about you in connection with the Services and any other related services that refer to or link to this Privacy Policy.  It does not apply to information that we receive and process as a “service provider” or “processor” to our customers, such as when we store data purely to assist our clients in facilitating their own marketing, or providing data storage and related services.

    This Privacy Policy does not apply to our processing or use of personal data in connection with employment by ROR.  If you are an employee or former employee of ROR, please contact our Human Resources office for more information.

  2. Summary Description of Our Services and Note Regarding Mobile Applications.

    ROR’s Services include, without limitation:  (a) intake of data from “Data Sources” (which are defined in Section 3 below); (b) the development of marketing audiences for Clients using, among other tools, data received from Data Sources; (c) the creation of marketing collateral for Clients; (d) the execution of marketing campaigns for Clients (including, for example, email marketing campaigns, direct mail campaigns, and campaigns involving website ads and other digital channels); (e) the provision to Clients of analytics and reporting regarding industry performance, campaign performance, and other metrics. Additionally, ROR may otherwise use data received from Clients in ways specifically directed by such Clients.

  3. Data Sources.

    ROR collects personal data through a variety of means, including, without limitation, by observing your online interactions with our Clients and advertisements, through third party data partners, and from public sources (collectively, “Data Sources”).  

    Description of Data Sources:

    1. Directly from You.  We receive data directly from you to, for example, support information and data requests (e.g., for the maintenance of any so-called “opt-out” requests and to respond to your information and privacy requests regarding you).  

    2. Indirectly from You.  We utilize certain automated technologies including, for example, cookies, pixels, and log files to collect information from you when you view or otherwise interact with our Clients’ websites where these technologies have been implemented, when you interact our Clients’ mobile applications where these technologies have been implemented, and/or when you view or interact with advertisements implemented as part of the Services.  

    3. Data from Clients.  We receive data about you directly or indirectly from our Clients, including, for example, personal data that our Clients have collected about you prior to their engagement of ROR.  

    4. Inferences from Other Data.  We create new personal data attributes and/or derive probabilities that a data attribute may be linked to you by using personal data that we collect combined with analysis and modeling.  

    5. Third Parties.  We receive additional information about you from various other companies, including, without limitation:

      1. Advertising Networks
      2. Other Advertising and Marketing Companies
      3. Loyalty and Rewards Companies
      4. Data Analytics Providers
      5. Data Compilers
      6. Health and Fitness Product and Services Companies
      7. Wellness and Lifestyle Companies
      8. Social Networking/Media Companies
      9. Consumer Survey Providers
      10. Sporting Goods Companies
      11. Public Databases
      12. Other Commercially Available Sources
      13. Service Providers

      Please be aware that Data Sources may contain links to third party sites or be hosted on platforms or devices that are not owned or controlled by ROR.  Please be aware that we are not responsible for the privacy or other practices of any such sites, platforms, or devices that we do not own or control.  We encourage you to be aware when you leave our Data Sources, and to read the privacy policies of every website you visit and mobile applications you use.

  4. Categories of Personal Data Processed.

    We collect, process, and use the following types of personal data:

    1. Contact Information and Other Individual Identifiers.  Examples:  name, email address, physical address, telephone number, IP address, mobile ad identifier.

    2. Transactional Information.  Examples:  goods and services purchased or viewed, purchasing, and viewing histories and tendencies.

    3. Demographic Information.  Examples:  age, gender, marital status.  

    4. Inferential Information, meaning inferences drawn from the other types of information described in this Section 4.  Inferences may also be used to predict certain of your characteristics, preferences, predispositions, and behaviors.  

    5. Internet and Other Network Activity Information.  Examples:  browsing histories, search histories, indication of online interests (such as consumer interests) derived from online activity, information on your interaction with a website, application, and/or advertisement.

    6. Mobile Application Data, meaning data described in this Section 4 derived from your interactions with any mobile application owned or controlled by any of our Clients, including, without limitation, the types of information described in Section 3 above and the dates and times the app on your device access our and/or our Clients’ servers.  

    7. General Employment Information.  Examples:  employer information, area of occupation or profession.

    8. Education Information.  Examples:  level of education, professional certifications.

    9. Client-Directed Processing of Information, meaning we may receive information described elsewhere in this Section 4 and/or additional information where expressly directed by Clients. 

  5. Uses of Personal Data.

    ROR collects and uses personal data regarding you for the following:  

    1. Placement of Internet-Based Advertising.  ROR’s Services include assisting companies with the placement of personalized advertisements on the Internet and on mobile applications.  You may be provided advertisements based upon:  (i) the content of any webpage you are visiting; (ii) the personal data we have collected regarding you; (iii) other activity you have undertaken on the Internet and/or on mobile applications; and/or (iv) inferences derived from any information we have collected regarding you.  

    2. Placement of Traditional Advertising.  ROR’s Services include assisting companies with the placement and distribution of advertising by email, direct mail, and by other means.  You may be provided these types of advertisements based upon:  (i) the content of webpages you have visited; (ii) the personal data we have collected regarding you; (iii) other activity you have undertaken on the Internet and/or on mobile applications; and/or (iv) inferences derived from any information we have collected regarding you.  

    3. Marketing and Analytics Purposes.  We collect personal data from Data Sources to create profiles of consumers (“Profiles”).  These Profiles are meant to assist ROR and its Clients with predicting future consumer preferences and the building of brand recognition and loyalty.  The Profiles are further utilized to create “audiences” whereby ROR’s Clients are able to connect with groups of actual and potential customers in both traditional and online marketing channels, such as online advertising and direct mail marketing.  In addition, ROR keeps and maintains Profiles for the purpose of providing Clients with analytics and business intelligence related to marketplace trends within a Client’s industry and/or related industries.  

    4. Operation and Improvement of ROR’s Services.  We utilize personal data from the Data Sources in connection with:  (i) testing, improving, updating and otherwise modifying our Services; (ii) developing new products and services; and (iii) analyzing and securing the Services.  

  6. Disclosures of Personal Data.

    1. Disclosure to Third Parties.  In connection with the purposes described in Section 4 above, we may disclose your personal data to third parties, including, without limitation, vendors and contractors of ROR and our Clients.  Any and all of the information described in Section 4 may have been “shared” and/or “sold” within the definition of those terms provided by privacy laws in the various States of the United States and/or Canada with or to the following categories of third parties in the past 12 months:

      1. Advertising Networks

      2. Other Advertising and Marketing Companies

      3. Loyalty and Rewards Companies

      4. Data Analytics Providers

      5. Health and Fitness Product and Services Companies

      6. Wellness and Lifestyle Companies

      7. Social Networking Companies

      8. Consumer Survey Providers

      9. Sporting Goods Companies

      10. Other Retailers

      11. Online Providers of Consumer Services and Products

      12. Business Services Companies and Agencies

      13. Consumer Data Resellers

      14. Consumer Services Companies

      15. Marketing Data and Analytics Companies

      16. Computer Technology and Software Providers

      17. Cloud Computing Providers

      18. Cloud Storage Providers

      19. Cloud SaaS Providers

      20. Educational Institutions and Companies

      21. Food and Beverage Companies

      22. Travel and Leisure Companies

    2. Disclosure to Service Providers for a Business Purpose.  We may disclose your personal data to our service providers and vendors that assist us with our business purposes (provision of the Services).  These service providers and vendors are only to process or otherwise use your personal data in accordance with our written instructions and only for the purposes listed in the table below.  The table below indicates the categories of applicable service providers and the respective business purposes with which they assist us.

      Categories of Personal Data

      Categories of Service Providers

      Business Purpose

      • Contact information and Other Individual Identifiers

      • Transactional information

      • Demographic Information

      • Mobile Application Data (e.g., mobile ad identifiers)

      • Advertising Networks

      • Other Advertising and Marketing Companies

      • Loyalty and Rewards Companies

      • Data Analytics Providers

      • Social Networking Companies

      • Consumer Survey Providers

      • Business Services Companies and Agencies

      • Consumer Data Resellers

      • Consumer Services Companies

      • Marketing Data and Analytics Companies

      • Processing or fulfilling orders and transactions

      • Verifying customer information

      • Providing analytic services

      • Providing marketing services

      • Contact Information and Other Identifiers

      • Transactional Information

      • Demographic Information

      • Inferential Information

      • Internet and Other Network Activity Information

      • Professional or Employment Information

      • Mobile Application Data (e.g., mobile ad identifiers)

      • General Employment Information

      • Education Information

      • Computer Technology and Software Providers

      • Cloud Computing Providers

      • Cloud Storage Providers

      • Cloud SaaS Providers

      • Provide computing services on behalf of ROR 

      • Provide storage on behalf of ROR 

      • Provide processing services on behalf of ROR



         

    3. Other Disclosures to Third Parties.  We may also disclose any or all of your personal data in connection with the following purposes:

      1. In Connection With Legal or Compliance Processes.  We may disclose your personal data to third parties in order to:  (A) comply with applicable laws, regulations, and/or governmental directives (collectively, “Applicable Laws”), or as otherwise necessary or appropriate in connection with any regulatory investigation or process; (B) in order to enforce contracts to which we are a party or this Privacy Policy, including, without limitation, investigating potential violations of the foregoing; (C) respond to allegations that our use of personal data infringes or violates the rights of anyone; and/or (D) protect the rights, property, or personal safety of us, our platforms, our Clients, and/or our vendors and contractors.  We may also provide personal data where appropriate to third parties (including, for example, law enforcement) in connection with fraud protection, spam/malware preventions, and/or other similar purposes.

      2. Disclosure in Connection with Corporate Transaction.  We may disclose personal data in connection with a major corporate transaction involving some or all of ROR, such as a merger, acquisition, sale of assets or ownership interests, investment, capitalization, financing, reorganization, consolidation, bankruptcy, liquidation, and/or in connection with a due diligence process associated with any of the foregoing types of transactions.  

      3. Disclosure to Other Types of Service Providers.  We may disclose personal data to other types of service providers who provide services to ROR, such as tech and customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement, hygiene, and/or other services meant to assist us with the Services and/or our business generally.

  7. ROR Services as a Data Processor.

    Most of our Services are performed in the role of a data processor or “service provider”.  In connection with our “service provider” Services, our Clients determine entirely how to engage with their actual and potential customers, and so our Clients are the “controller” or “business” with respect to personal data in those circumstances.  In those circumstances, consumers are ultimately subject to the privacy policy of the applicable Client controlling their personal data, and consumers should refer to that policy and review it closely.  Accordingly, this Privacy Policy does not apply to personal data where any of our Clients is the “controller” of consumers’ personal data.  ROR is not responsible for the privacy policies or data protection practices of any of our Clients.  While ROR strongly encourages its Clients to adopt legally compliant and industry-standard approaches to personal data, we are not responsible for the practices or policies of any of our Clients.

  8. Retention of Personal Data.

    We retain personal data for as long as is necessary or appropriate to facilitate the purposes described in this Privacy Policy or as necessary or appropriate to comply with Applicable Laws, and/or as otherwise necessary or appropriate to protect our or others’ rights.  When we no longer need or elect to retain personal data for the foregoing purposes, we remove it from our systems or de-identify the personal data and archive it in accordance with our internal data retention and maintenance policies. 

  9. Your Rights and Choices.

    Your Rights. 

    The laws of the jurisdiction in which you reside (such as the states of California, Connecticut, Virginia or Colorado, or the provinces or country of Canada) may give you certain data privacy rights, including the right to access, correct, and delete personal data, subject to certain exceptions and limitations.  We describe those rights further in below Sections of this policy. 

    Regardless of your residence, however, anyone may request to be “opted out” of our data services and licensing platforms, by submitting our online request form located at www.rorpartners.com/dsar, by calling us at 1-888-914-9661 PIN: 654417, or by emailing us at privacy@rorpartners.com.  

    Your Advertising Choices. In addition to any rights you may have under the laws of your jurisdiction of residence, you may elect not to receive targeted advertising from ad networks, data exchanges, and other digital advertising providers by opting out of targeted advertising via Your Ad Choices (in the US) or Your Ad Choices (in Canada) powered by the Digital Advertising Alliance.

    Do Not Track. 

    Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit.  However, there is no industry consensus as to what websites should do with regard to these signals.  As such, please note that we do not monitor or act with respect to “Do Not Track” signals.

    California “Shine the Light” Law. Under California’s “Shine the Light” law, businesses that sell their customers’ personal information to third parties for those third parties’ direct marketing purposes must provide an opt-out or offer a list of such third parties.  We do not sell our customers’ personal information in that way.  However, if you are more generally interested in “opting out” of the sale of other personal information we may collect, please go to Section 11 below.

    Cookies and Other Similar Technologies; Social Media Plugins. For more information about our use of cookies and other similar technologies and our use of social media plugins, and your choices regarding the foregoing, see the Section below titled, “Use of Cookies, Other Tracking Technologies, Social Media and Social Media Plug-Ins”.

  10. Additional Information for Nevada Residents.

    Nevada state law (NRS 603A.340) requires businesses to establish a designated request address where Nevada consumers may submit requests directing the business not to “sell” certain kinds of personal data that the business has or will collect and retain about the consumer.  A “sale” under Nevada state law is the exchange of personal data for monetary consideration by a business to a third party for the third party to license or sell the personal data to other third parties.  If you are a Nevada consumer and you wish to submit a request relating to our compliance with Nevada state law, you can make the request by visiting https://www.rorpartners.com/dsar and completing the request form, calling us at 1-888-914-9661 PIN: 654417 or emailing us as privacy@rorpartners.com.

  11. Additional Information for Residents of California and Other Applicable States.

    The California Consumer Privacy Act ("CCPA"), Colorado Privacy Act (“CPA”), and several other applicable U.S. state privacy laws (collectively, “State Privacy Laws”) require that we provide residents of these states with information about how we use their personal information and this Section is intended to satisfy that requirement.  These State Privacy Laws either are currently effective or will become effective on various dates in the future.  

    This Section, in turn, applies solely to the extent that State Privacy Laws have become effective and apply to us.  In addition, this Section applies solely to residents of California, and other U.S. states (including but not limited to Colorado, Connecticut, Virginia and Utah) that have enacted State Privacy Laws, with such residents referred to in this Section as “Consumers.”  As used in this Section, “you”, “your”, and “yours” refer to Consumers. As used in this Section, “personal information” includes “personal data” and “personal information” as defined in State Privacy Laws, and means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. 

    Your Rights Under State Privacy Laws. Subject to certain exceptions, State Privacy Laws grant you the right to request that we do the following:

    • Provide you with the categories of personal information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for collecting, “selling,” or “sharing” your personal information; the categories of third parties to whom we disclose or “sell,” or with whom we “share,” personal information; and the categories of personal information we “sell” or “share” (much of which is provided above and below).

    • Provide access to and/or a copy of certain personal information we hold about you.

    • Delete certain personal information we hold about you.

    • Correct inaccurate personal information we hold about you.

    • Opt you out of the “sale” or “sharing” of your personal information.

    Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the services to you. If you ask us to delete it, you may no longer be able to access or use the services.

    Submitting Requests.  To exercise these rights, you may complete the request form at https://www.rorpartners.com/dsar or call us at 1-888-914-9661 PIN: 654417.  We may seek to verify your identity prior to responding to your request.  Authorized agents may initiate a request on behalf of a Consumer (and we may confirm this request with the individual), and will be required to provide written proof of their authorization or (in the case of a request for access to personal information) a valid power of attorney.  We may be required to verify the Consumer’s identity with the Consumer themselves. We do not discriminate against Consumers for exercising their rights under State Privacy Laws.

    California Residents Only: Right to Limit Use of Sensitive Personal Information. We generally do not collect for our commercial purposes information that is considered “sensitive” under state laws, such as information revealing an individual’s medical condition, ethnicity, religion, or sexual orientation.  However, if you believe that we have collected such information from you, you may contact us and request that we limit the use or disclosure of your “Sensitive Personal Data” by calling us at 1-888-914-9661 PIN: 654417 or by contacting us by email at privacy@rorpartners.com.   

    Certain States Only: Right to Appeal. Certain Consumers (including Colorado residents) have the right to appeal a denial of a privacy rights request.  Within 60 days of receiving a denial of a request made pursuant to this Privacy Policy from us, you may make an appeal by visiting https://www.rorpartners.com/dsar and completing the request form, or by calling us at 1-888-914-9661 PIN: 654417.

    Financial Incentives. We do not provide financial incentives in exchange for personal data.  However, we may work with partners that provide loyalty or rewards programs that provide financial incentives in exchange for rewards, discounts or, other benefits. 

    Categories of Personal Information We Collect. The table below identifies the categories of personal information we have collected about Consumers in the past 12 months.

    Categories 

    Description (examples listed below for each category are statutory; thus, all may not be collected in the data we collect)

    Identifiers 

    Includes direct identifiers, such as name, alias user ID, username, account number or unique personal identifier; email address, phone number, postal address and other contact information; IP address and other online identifiers; and other similar identifiers. 

    Customer Records

    Includes personal information, such as name, account name, user ID, contact information, employer, account number.  For example, this may include information collected when an individual registers for an account, purchases or orders our products and services, or enters into an agreement with Clients related to our products and services. 

    Protected Classification Data

    Includes age (over 40) and gender. 

    Commercial Information 

    Includes records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. For example, this may include demographic information that we receive from third parties to better understand and reach our customers. 

    Usage Data 

    Includes browsing history, clickstream data, offline behavior (e.g., health and fitness interests), access logs and other usage data and information regarding an individual’s interaction with our Data Sources and other services, and our marketing emails and online ads. 

    Geolocation Data

    This may be collected when you check into a Client’s facility. 

    Professional information 

    Includes professional and employment-related information (such as current and former employer(s) and position(s), business contact information). For example, if your employer sponsors your membership plan with Clients. 

    Inferences 

    Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, abilities, or aptitudes. For example, we may analyze personal information to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads. 

    Sources of Personal Information. We may collect information from the sources described in Section 3 above. 

    Purposes and Disclosures. For more information about the business and commercial purposes for which we collect, use, disclose and/or sell personal information and the third parties with whom we may disclose or sell your personal information, please see Section 4, Section 5, and Section 6 above. 

    Retention. We may retain personal information we collect as described in Section 8 above.

    “Sales” and “Sharing.” Please note that under State Privacy Laws, a “sale” includes disclosing or making available personal information to a third party in exchange for monetary compensation or other benefits or value. Under this strict definition, for instance, when audience information derived from online or offline activity is made available to third party ad companies (through third party tags on our Data Sources) to improve and measure ad campaigns and reach users with more relevant ads and content, that is likely a “sale” of information (as “sale” is defined in State Privacy Laws).  Thus, we may “sell” certain categories of personal information including Inferences, Usage Data and Identifiers to third party advertising networks and data analytics providers.  For instance, if you have expressed interest in fitness activities (or, e.g., frequently attend a health club) we might place you into an “audience” segment related to fitness and help health clubs in your area send you discounts or offers.  However, you may opt-out of any “sale” of your personal information by visiting https://www.rorpartners.com/dsar and completing a request or calling us at 1-888-914-9661 PIN: 654417.  We do not “sell” personal information about Consumers who we know are younger than 16 years old.  

        For More Information Please Visit: Your Privacy Rights and Opt-Out Rights 

    In addition, State Privacy Laws give you the right to opt out of our use of your information for: (a) purposes considered a “share” under Applicable Laws; and/or (b) cross-content behavioral advertising or targeted advertising (what we refer to above as Internet-Based Advertising). You may opt out of these uses of your personal information by visiting https://www.rorpartners.com/dsar and completing the request form, or by calling us at 1-888-914-9661 PIN: 654417.

    Please note that you may set opt-out preference signals by sending the “Global Privacy Control.”  Many companies, including companies that we partner with, recognize and honor these signals in the course of serving third party behavioral advertising, and similar data transmissions that may be considered “sales” under relevant privacy laws.   For more information on how to use the Global Privacy Control (such as through implementation of a browser extension) see www.globalprivacycontrol.org. 

    Categories of third parties to whom Personal Information has been disclosed for a business purpose include service providers, advisors and agents, advertising networks, data analytics providers, internet service providers, operating systems and platforms, social networks, employers, and government entities and law enforcement.  (See also Section 6 of the Privacy Policy, for additional information about data recipients.)

  12. Canadian Residents’ Right to Withdraw Consent.

    If you are a resident of Canada, you may request a withdrawal of your consent to our processing your personal data.  To do so, please visit https://www.rorpartners.com/dsar and complete a deletion request or call us at 1-888-914-9661 PIN: 654417.
    Please be aware that we may nevertheless retain certain personal data: (a) to maintain a record of the deletion request; and/or (b) as Applicable Laws may allow or require.

  13. Use of Cookies, Other Tracking Technologies, Social Media and Social Media Plug-Ins.

    1. Cookies.  Cookies are small pieces of text or code sent to your computer or device when you visit a website.  They are used to optimize the viewing experience, keep websites secure, and to orient content toward the visitor.  ROR uses the following types of cookies on its website and/or may place the same types of cookies on a Client’s website and/or mobile application in connection with the provision of Services.  These cookies may be placed by ROR, a Client, and/or a vendor or contractor of ROR.

      1. Performance cookies that are used to identify the pages visited and to improve our website and/or our Client’s website and/or mobile application.

      2. Functional cookies are used to provide the services you request.  These cookies remember your preferences in order to improve the user experience on our website and/or our Client’s website and/or mobile application.

      3. Targeting cookies may be used to build or link to a profile of your online or offline interests and show you relevant advertisements through display media, mobile devices, email, direct mail or connected TVs.  If you or a Client does not allow these cookies, the advertising you are provided will likely be less relevant to you.  

      Please be aware that the cookies used by ROR may be created or deployed by third parties and not ROR.  Our (and/or our Client’s) use of cookies is intended to provide you with a better website and/or mobile application experience by enabling us to determine which pages you find useful and which you do not.   Our website will (and our Client’s websites and/or mobile applications are required to by contract to) allow you to accept or decline cookies.  The default settings of many web browsers will automatically accept cookies, but you can typically modify your settings to decline them.  Declining cookies may prevent you from taking full advantage of our website and/or our Client’s website or mobile application.

    2. Web Tags.   We may use “web tags”, which are small graphics or JavaScript code that allow us to monitor the use of Client websites and mobile applications. A web tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the web tag appears; the time the page containing the web tag was viewed; the type of browser that fetched the web tag; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, we may use "format sensing" technology, which allows web tags to let us know whether you received and opened our email.

    3. Plug-Ins.  We use Meta and Instagram social plugins on our Data Sources. When you view a Data Sources that contains a plug-in, your browser will create a direct link to the third parties’ servers. If you are logged into your social media account, the social media platform will record the visit to your social media account. Please visit the applicable social media platform’s privacy policy for more information.

  14. Security and Data Integrity.

    We seek to ensure that the personal data that we process is stored and transmitted securely.  Our security measures may include various types of physical and electronic security, such as firewalls, encryption, hashing or truncation of data, and internal access controls regarding personal data.  However, neither we nor any of our vendors, contractors, and/or Clients can guarantee that the electronic storage and/or transmission of data is fully secure, and you should be careful in submitting any personal data online.

  15. Minors.

    We do not knowingly collect personal data (as defined by the UC Children’s Privacy Protection Act, or COPPA) from children.  If you are a parent or guardian and believe we have erroneously collected personal data from any children, as defined by COPPA, please email us at privacy@rorpartners.com, and we will take appropriate steps to secure or delete such data.

  16. Changes to Privacy Policy.

    We may periodically update this Privacy Policy.  Any changes to this Privacy Policy will be effective when they are posted to our website.  The date of the last modifications to this Privacy Policy is indicated at the top of this Privacy Policy.  

  17. Questions.  

    If you have any questions relative to this Privacy Policy or your rights or privacy choices, or seek more information about our privacy practices, please email us at privacy@rorpartners.com.  You may also send additional correspondence to:

    ROR Partners, LLC
    6543 S. Las Vegas Blvd.
    2nd Floor
    Las Vegas, NV 89119