Last Revised: August 8, 2024
Your privacy is important to RENFROE, and we are committed to protecting the privacy of all individuals. We provide the website at https://earenfroe.com/ (the "Website") for your convenience and informational purposes. The "Services" discussed in this Policy are the information, classes, services, and methods of communication we provide through the Website. We will not conduct business with you solely through our Website.
For our employees and contractors, the Website also provides access to the RENFROE Portal which you may use to perform your job (the "Portal").
This Privacy Policy ("Policy") answers questions about:
All capitalized terms in this Policy are defined in the DEFINITIONS section of this Policy.
When we collect data as part of the Services or through the Portal, RENFROE determines how that data is Processed, and RENFROE is the Controller (as defined in the Privacy Laws). Contact RENFROE with any questions about how we Process your Personal Information. Click this link for our CONTACT INFORMATION.
This Policy applies to all information we collect on or as a result of your accessing or using the Website, the Services or the Portal. This Policy does not apply to information we collect offline or through any other means, including through websites or mobile applications that do not incorporate this Policy or from third parties that may link to or be accessible from or through the Website.
Please read this Policy carefully. By accessing or using the Website, the Services, or the Portal you agree to us Processing your information as described in this Policy. This Policy may change from time to time. You should review UPDATES TO THIS PRIVACY POLICY to understand when and how it might change. Your continued use of the Website, the Services or the Portal after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.
If you do not agree to us Processing your information as stated in this Policy, do not use the Website, the Services, or the Portal or submit any Personal Information to us.
All information we Process about individuals is either Personal Information or Non-Identifying Information. We may use the Personal Information and the Non-Identifying Information to create Aggregated Information. We do not collect Sensitive Personal Information through our Website. We do collect Sensitive Personal Information about employees and contractors who use the Portal.
We collect information:
You may provide us information in the following ways:
For our employees and contractors, we may use the Portal to collect images of governmental identification such as your driver's license, passport or other information that allows us to verify your eligibility for employment or contractor status or your (or your dependents') eligibility for insurance or other benefits.
As you navigate through and interact with our Website or the Portal, we may use automatic data collection technologies to collect information about your equipment, browsing actions, and usage patterns. That information may include:
We may also collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please see COOKIE POLICY (ONLINE TRACKING TECHNOLOGIES) for information on how we use these technologies. Please see YOUR INFORMATION – YOUR CHOICES for information on your rights concerning the information we Process and EXERCISING YOUR RIGHTS for information on how to exercise those rights.
The information we collect automatically is only statistical data and does not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. We may use this information to help us improve our Website and the Portal and to deliver a better and more personalized service, including by enabling us to:
Analytics tools are a specific type of automatic data collection tools. For a complete list of the analytic tools we use and how we use them, please see COOKIE POLICY (ONLINE TRACKING TECHNOLOGIES).
We use information from third parties to supplement or update the information you provide to us or that we collect from you automatically. For example, we may use a third-party service to verify or update your postal addresses when shipping something to you. Examples of other information we might receive from third parties are:
Except for images of governmental identification that may include photographs of you, we do not collect biometric information or sensory data on the Website or the Portal. We do not collect non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)).
Category Examples Collected Identifiers: real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiersYESPersonal information categories listed in the California Customer Records statute
(Cal. Civ. Code § 1798.80(e))A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. (Some Personal Information included in this category may overlap with other categories.)YES Protected classification characteristics under California or federal lawAge (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)NO for visitors to the website
YES for employees and contractors using the Portal.Commercial informationRecords of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendenciesNOBiometric informationGenetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise dataNOInternet or other similar network activityBrowsing history, search history, information on a consumer's interaction with a website, application, or advertisementYESGeolocation dataPhysical location or movementsYESSensory dataAudio, electronic, visual, thermal, olfactory, or similar informationNOProfessional or employment-related informationCurrent or past job history or performance evaluationsNO for visitors to the Website.
YES for employees and contractors using the Portal.Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary recordsNOInferences drawn from other Personal InformationProfile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudesYES
We also collect Non-Identifiable Information, such as your preferred language, zip code, area code, referrer URL, and the time zone where the Website or Portal is accessed. We use this information to understand user behavior better and improve our Services. We also may collect information regarding user activities on our Website or Portal and aggregate that information to help us provide more useful information and Services to our users, employees and contractors. This Non-Identifiable Information also helps us understand which parts of our Website, the Services and the Portal are most interesting. Aggregated data is considered Non-Identifiable Information for the purposes of this Policy.
If you provide us any Personal Information about another individual, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Information in accordance with this Policy.
You are responsible for ensuring the accuracy of Personal Information you provide to us. Inaccurate information may affect your use of the Services, our ability to manage details of your employment or contract, and our ability to contact you. Visitors to the website are not required to provide Personal Information to us, but if you choose not to do so, we may not be able to provide you with our Services or respond to any questions you may have. Employees and contractors are required to provide certain Personal Information to us to obtain or maintain their status as an employee or contractor.
Consistent with applicable law and the choices and controls you select EXERCISING YOUR RIGHTS, we may use your information as described in this Policy. Some examples of how we may use your information are:
To learn more about how we use your information for personalization and tracking, please see COOKIE POLICY (ONLINE TRACKING TECHNOLOGIES).
We have determined that our legal basis for the different types of data processes is as follows:
Our legal basis for:Is:Processing data allowing us to get in touch with youOur legitimate interests, namely, the proper administration of our business or the performance of a contract between you and us and the proper management of our employees and contractorsProcessing your personal data to operate our Website, processing and fulfilling orders, providing our services, supplying our goods, generating invoices, bills, and other payment-related documentation, and credit controlOur legitimate interests, namely the proper administration of our Website, Portal, Services, and business, or the performance of a contract between you and us, or taking steps, at your request, to enter into such a contractProcessing your Personal Information to publish your information on our Website and elsewhere through our Services following your express instructionsYour consent; or our legitimate interests, namely the publication of content in the ordinary course of our operations, or the performance of a contract between you and us or taking steps, at your request, to enter into such a contractProcessing your contact data, account data, transaction data, or communication data to manage our relationships, communicating with you (excluding communicating for direct marketing) by email, SMS, post, fax, or telephone, providing support services, and complaint handlingOur legitimate interests, namely, communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our Website, services, and businessProcessing usage data or transaction data to research and analyze the use of our Website and services, as well as researching and analyzing other interactions with our businessYour consent; or our legitimate interests, namely, monitoring, supporting, improving, and securing our Website, Portal, Services, and business generallyProcessing your personal data to create and maintain our databases, backup copies of our databases, and our business records generallyOur legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this noticeProcessing your personal data for security and the prevention of fraud and other criminal activityOur legitimate interests, namely the protection of our Website, Portal, Services, and business, and the protection of othersProcessing your personal data where necessary for obtaining or maintaining insurance coverage, managing risks, or obtaining professional adviceOur legitimate interests, namely the proper protection of our business against risksProcessing your personal data where necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or an administrative or out-of-court procedureOur legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of othersProcessing your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural personOur legitimate interests, namely the proper protection of our business against risks
RENFROE strives to collect only the Personal Information we need for our business. We do not sell or share your Personal Information in exchange for money.
Some privacy laws define the sale of data to include sharing Personal Information for a business purpose. We may sell or share your Personal Information with a third party for a business purpose, but when we do so, we enter into contracts requiring those third parties to keep your Personal Information confidential and to use your Personal Information only for the permitted purpose. This sharing of Personal Information includes about our employees and contractors with our clients.
We may share your Personal Information in the following situations:
We may disclose Aggregated Information or Non-Identifying Information for any reason without restriction.
During this time, we disclosed Personal Information for business purposes to the categories of third parties indicated in the chart below.
Personal Information Category Category of Third-Party Recipients IdentifiersAffiliates, Service Providers, Business Partners, Social MediaCalifornia Customer Records Personal Information categoriesAffiliates, Service Providers, Business Partners, Social MediaProtected classification characteristics under California or federal lawN/ACommercial informationAffiliates, Service Providers, Business Partners, Social MediaBiometric informationN/AInternet or other similar network activityAffiliates, Service Providers, Business Partners, Social MediaGeolocation dataAffiliates, Service Providers, Business Partners, Social MediaSensory dataN/AProfessional or employment-related informationAffiliates, Service Providers, Business Partners, Social MediaNon-public education informationN/AInferences drawn from other Personal InformationN/ALog-in, Account, or Financial Card Number, in combination with required Access CodeN/A
We provide the ability to exercise certain controls and choices regarding our collection, use, and sharing of your information. Under applicable law, your controls and choices may include:
You have the right to know what Personal Information we collect about you. Upon receipt of your request and confirmation of your identity, we will disclose to you:
In most cases, you may request this information up to two times each year.
You have the right to request a copy of the Personal Information we have about you. We will provide it in a format that we select that you can reasonably transfer to a third party.
You have the right to request that we correct inaccurate Personal Information that we maintain about you, subject to applicable legal exceptions. Employees and contractors may make such changes in the Portal.
You have the right to request that we delete any of your Personal Information, subject to applicable legal exceptions. We will not delete any Personal Information we are required to maintain as a result of your employment or contractor status with RENFROE. If you submit a request for your Personal Information to be deleted, we will review your request and attempt to confirm your identity. If we confirm your identity, we will review the request to see if an exception allowing us to retain the information applies. If no exception applies, we will delete your Personal Information and direct our service providers to do the same.
We may deny your deletion request, for example, if retaining the Personal Information is necessary for us or our service provider(s) to:
If you do not wish to have your email address or other contact information used by RENFROE to promote our products or services, you can opt out of non-essential email or text communication by contacting us as provided in CONTACT INFORMATION. If we have sent you a promotional email or text, you may send us a return email or text asking us to omit you from future email distributions.
Your election not to receive promotional and marketing correspondence from RENFROE will not (a) preclude us from corresponding with you, by email, text, or otherwise, regarding your existing or past relationship with us, nor (b) preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your Personal Information while maintaining and improving the Website.
RENFROE does not use targeted advertising or engage in profiling.
You have the right to "opt-out" of the "sale" or "sharing" of your Personal Information to or with "third parties" (as those terms are defined by applicable law). There may be situations where we cannot fulfill your requests if you opt out of such sharing. If that is the case, we will make it clear at the time of collection that such sharing is required to fulfill your request for products or services.
You may also use an authorized agent to submit a request to opt-out on your behalf if you provide the authorized agent signed written permission to do so. To opt out of the sale or sharing of your Personal Information, you or your authorized representative should:
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back into Personal Information sales at any time by emailing legal@earenfroe.com.
You do not need to create an account with us to exercise your opt-out rights. We will use Personal Information provided in an opt-out request only to review and comply with the request.
To exercise any of your rights, submit a request to:
When submitting a request, you must:
Only you or someone legally authorized to act on your behalf may make a request regarding your Personal Information. A parent or guardian with legal custody may make a request on behalf of a minor child. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney under applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you have given your permission or to verify your identity.
We cannot, and will not, respond to your request or provide you with Personal Information if we cannot verify your identity or your authority to make the request and confirm the Personal Information relates to you. We will not use Personal Information provided in the request for any purpose other than to verify the requestor's identity or authority to make the request.
In certain circumstances, you are permitted to use an authorized agent, as that term is defined by applicable privacy laws ("Authorized Agent") to submit requests on your behalf where you provide sufficient evidence that the requestor is an authorized agent with written permission to act on your behalf and you successfully verify your own identity with us. An Authorized Agent can make a request on your behalf by:
We endeavor to confirm receipt of all requests within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email legal@earenfroe.com to ensure we received your request.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically to the address we have on file for you (not the address you specified in your request).
The information in our response will cover the 12-month period preceding our receipt of your request. If we cannot comply with your request or any portion of your request, our response will explain why we cannot comply. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If we refuse to act upon your request to exercise any of your data privacy rights, you may appeal our decision within a reasonable period after you receive notice of our decision. To initiate an appeal, please contact us using the information in the CONTACT INFORMATION section and inform us that you would like to appeal our decision. Within forty-five (45) days after we receive your appeal, we will inform you of any action taken or not taken in response to your appeal, and we will provide you with a written explanation of the reasons in support of our response.
If your appeal is denied, we will also provide you with information on contacting your state attorney general to submit a complaint, should you wish to do so.
We will not discriminate against you for exercising any of your data protection rights, and specifically, we will not:
However, we may offer certain financial incentives permitted by applicable Privacy Laws that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Please be aware that if you do not allow us to collect Personal Information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our products/services may not be able to take account of your interests and preferences. For employees and contractors, you are required to submit certain Personal Information to be eligible for employment or a contract. If you choose not to provide any optional Personal Information, you may not be eligible for certain assignments. If collection of Personal Information is mandatory for successful provision of products/services, we will make that clear at the point of collection so that you can make an informed decision whether to participate.
Our Website is not intended for children under 16 years of age. No one under age 16 may provide Personal Information to or on the Website. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at legal@earenfroe.com.
Your information's security, integrity, and confidentiality are extremely important to us. We have implemented technical, administrative, and physical security measures to protect your information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We will retain your Personal Information for the time needed to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
If it is necessary to transfer your Personal Information to another country for Processing in accordance with this Policy, we will use the appropriate Standard Contractual Clauses Module, as amended from time to time by the European Commission.
Occasionally, we may change this Policy to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. We will post any changes to this Policy on the Website with a notice the Policy has been updated. The date the Policy was last revised is at the top of the page.
If you have a comment or question about this Policy, please contact us at:
AGGREGATED INFORMATION is information about groups or categories of data subjects or individuals that does not identify and cannot reasonably be used to identify an individual.
NON-IDENTIFYING INFORMATION is any Information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual, household, or device.
PERSONAL INFORMATION is any Information that relates to, describes, references, is reasonably capable of being associated with, is linked to, or could reasonably be linked to, a particular individual, household, or device, such as an 'individual's name, postal address, email address, telephone number, or other online identifier.
POLICY is this Privacy Policy.
PROCESSING your information includes collecting, using, storing, disclosing, and otherwise manipulating your information.
SENSITIVE PERSONAL INFORMATION includes race or ethnicity; religion; citizenship; genetic data; biometric data used to identify a person; precise geolocation; Personal Information of children; union membership; SSN; DL or passport number; financial account with password or security code; contents of mail, email or texts (unless a business is the intended email recipient); medical and health information that does not otherwise constitute Protected Health Information (or "PHI"); and in the EU, criminal records.
SERVICES are the information, classes, services, and methods of communication we provide through the Website.
WEBSITE is the website accessible at https://earenfroe.com/.
California residents have the following rights:
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by RENFROE to third parties for the third 'parties' direct marketing purposes. We take great pride in the relationship of trust we have built over many years and are dedicated to treating your Personal Information with care and respect. Pursuant to California Civil Code Section 1798.83(c)(2), we do not share 'guests' Personal Information with third parties for those 'parties' direct marketing use unless you elect that we do so.
California Privacy Right Metrics
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This data reflects all requests received from individuals in the U.S. and certain requests from individuals outside the U.S. between January 1 and December 31, 2023.
*Requests may not be completed due to various factors, including because a request was not verifiable, was made multiple times, or where we did not have any Personal Information associated with the requester.
Nevada provides its residents a limited right to opt-out of certain Personal Information sales. Residents who wish to exercise this sale opt-out rights may do so as provided for in EXERCISING YOUR RIGHTS. However, please know we do not currently sell data triggering that statute's opt-out requirements.
We may use cookies, pixel tags, local storage, and other technologies to collect information through the Website or the Portal automatically. These technologies allow us to understand who has interacted with us and help us operate our Website, Portal and Services more efficiently.
There are different ways to classify cookies, including based on when they expire or whether we manage them or a third party.
Type of Cookie Description First Party Cookies First Party Cookies are those that may be managed by RENFROE and originate from our Website. Third Party Cookies Third Party Cookies originate with service providers or business partners providing services on or through our Website. These third parties can use them to recognize your device when it visits other websites. Third Party Cookies may also be used for other purposes, such as analytics, advertising, and social media features. Essential These cookies are necessary for the Website or Portal to function and cannot be switched off in our systems. Strictly necessary cookies are typically set in response to actions or services you request, such as setting your privacy preferences, logging in, filling out a form, or putting items in a shopping basket. Strictly necessary cookies can also be used to manage sessions on load-balanced servers or to ensure user requests are routed consistently to the correct server. You can set your browser to block these cookies or alert you about them, but some parts of the Website will not work if you select such settings.Analytics CookiesThese cookies count visits and traffic sources so the performance of our Website or Portal can be measured and improved, including determining whether a user is new or returning, distinguishing users from one another, and calculating new and returning visitor statistics. These cookies help us to know which pages are the most and least popular on the Website or Portal and to see how visitors move around the Website or Portal. For example, we use Google Analytics to help us understand how frequently the same people revisit the Website and Portal, how the Website and Portal are found (from advertising or referring websites), and which pages are most frequently viewed. All information collected through these performance cookies is aggregated and anonymous. This information is combined with data from many other users to create an overall picture of Website use. It is not identified individually or personally or linked to any other information we store about you.Preference CookiesThese cookies enable the Website to remember information that is used to reflect how the Website is displayed and changes from user to user, such as your preferred language or color scheme. These cookies also allow the Website to remember data that you type so that you do not have to re-enter it on subsequent visits.Marketing CookiesThese cookies are used to track visitors across Websites and allow publishers to display relevant and engaging advertisements.Statistics CookiesThese cookies are used to generate statistical reports and heat maps providing information on the use of different aspects of the Website.
RENFROE uses first and third party cookies that are classified as essential, preference, marketing, analytics, and statistics cookies. Specifically, RENFROE uses the following Cookies:
We use cookies to learn how you interact with our Website, the Portal and the Services, improve your experience, and provide you additional functionality on the Website and the Portal. We may also use pixels for the same purposes.
We work with limited third parties to provide certain services on the Website and Portal. These third parties include Facebook, LinkedIn, and X. They may use their cookies to collect information about your actions on our Website or the Portal. RENFROE does not control third-party cookies.
Please refer to their privacy policies for more information on how these third-party service providers collect and use information.
If you choose, you can set your browser to reject cookies, or you can manually delete individual or all of the cookies on your computer by following your browser's help file directions. However, if your browser is set to reject cookies or you manually delete cookies, this may alter your access and use of some of the pages and features on our Website.
Users can visit Google Analytics Opt-out Browser Add-on Download Page, https://tools.google.com/dlpage/gaoptout, for information on how to opt out of Google Analytics.
You may also reject or block all or specific types of cookies from our Website by setting your preferences. You can change those preferences at any time.
You may also visit https://allaboutcookies.org/ or https://www.aboutcookies.org/ for details on deleting, rejecting, or blocking cookies and general information on cookies.
Some web browsers may transmit "do-not-track" signals to the Website with which the user communicates. These are different from the Global Privacy Controls. The Website does not monitor or identify " do not track signals, " and such signals will not impact the operation of this Website.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website. You may have additional rights regarding your Personal Information based on the state in which you reside. Please see JURISDICTION SPECIFIC RIGHTS for more information.
