Privacy Policy

Last updated on April 11, 2020

1. Privacy Shield Framework

2. Collection of Personal Information

3. How Your Personal Information Is Used

4. Legal Bases for Processing

5. Information Sharing with Service Providers / Agents

6. Data Retention and Data Portability

7. Your Choices (Opt Out)

8. Protection of Your Personal Information

9. Cookie and Tracking Technologies

10. Changes in Privacy Policy

11. Non-Discrimination

12. Links to third party sites

13. Social Media Widgets

14. Single Sign-On

15. Referral Program Emails

16. Children

17. Privacy Complaints

Privacy Statement

This Privacy Statement describes how RetroSkier manage personal information and respect your privacy. This policy may be amended from time to time. We encourage visitors to and users of our sites to regularly review our Privacy Policy.

All "Personal Information" (which is defined as any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains) that we collect and maintain will be subject to this Privacy Policy, as amended from time to time.

When we refer to "RetroSkier", "we", "us" or "our" in this privacy notice, we mean the RetroSkier entity that acts as the controller or processor of your information, as explained in more detail in the "Entities Collecting Personal Information" section below.

1. Privacy Shield Framework

RetroSkier monitors its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield. RetroSkier plans to subject all personal data received from European Union (EU) member countries, United Kingdom (UK), and Switzerland, respectively, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list].

RetroSkier is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, RetroSkier may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

2. Collection of Personal Information

As a visitor to the Site, you can engage in many activities without providing any Personal Information. However, when you register to use a RetroSkier site and order products or services as a RetroSkier subscriber in order to provide the services to you, we may collect the following Personal Information from you:

• Contact information such as your name, phone and fax numbers, address and email address; and

• Billing information such as the number, expiration date, card type and billing address of your credit card;

• Demographic information such as your job title, job description and company name and company type; and

• Profile data, including your username and password, details about your purchases and the Content that you license from us.

If you submit content to RetroSkier, you may be asked to provide the following information:

• Contact information such as your name, phone number, primary address, and email address.

• Payment and contributor information including, but not limited to, payment method, desired display name, and content focus.

Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.

As is true of most websites, when you use the Site, RetroSkier or third party subprocessors contracted by RetroSkier may also collect certain technical and routing information about your computer to facilitate your use of the Site and its services. For example, we may log environmental variables, such as browser type, operating system, CPU speed, and the Internet Protocol (IP) address of your computer. We may use these environmental variables to facilitate and track your use of the Site and its services. RetroSkier may also use such environmental variables to measure traffic patterns on the Site. To better understand the needs of our visitors to the Site we may occasionally match such information with your Personal Information.

3. How Your Personal Information Is Used

RetroSkier collects your information in order to provide services to you, comply with our legal obligations, and to improve our products and services. We do not sell, rent or share your personally identifiable information to or with third parties in any way other than as disclosed in this Privacy Policy. RetroSkier may use this information to:

• Authenticate and provide access to the RetroSkier websites, mobiles applications, and services.

• Process your financial transactions.

• Send you order confirmations.

• Register your rights, if any, to technical support or other benefits that may be made available to registered users.

• Respond to customer service requests, questions and concerns.

• Administer your account.

• Send you requested product or service information.

• Keep you informed about special offers and services of RetroSkier and selected third parties.

• Administer promotions and sweepstakes you enter and notify you of the results.

• Investigate, prevent or take action regarding illegal activities and/or violations of our Terms of Service.

• Meet our research and product/service development needs and to improve our Site, services and offerings; and

• Customize your experience, including targeting our services, search results, and offerings to you.

We store information that we collect through cookies, log files, transparent images, and/or third party sources to create a summary of your preferences. We tie your personally identifiable information, and/or your membership usage history, to information in the summary, in order to provide tailored promotions and marketing offers, to improve the content of the site for you and/or to determine your preferences.

In certain situations, RetroSkier may be required to comply with legal obligations to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Where required by law (e.g., to comply with a subpoena, warrant, court order, or legal process served on RetroSkier), and when we believe that disclosure is necessary to protect our rights, avoid litigation, protect your safety or the safety of others, investigate fraud, and/or respond to a government request. We may also disclose information about you in order to comply with our legal obligations if we determine that such disclosure should be made for reasons of national security, law enforcement, or other issues of public importance.

4. Legal Bases for Processing

For individuals located in European Economic Area (EEA) and UK, we rely on the following legal bases for the processing of your personal data:

• Where processing is necessary to perform our contract with you:

o Providing access to the RetroSkier website, and services to fulfill the terms of your agreement;

o Customizing your experience, including targeting our services, search results, and offerings to you.

o Providing information so that you can make decisions about RetroSkier services;

o Processing your financial transactions and sending you order confirmations;

o Register your rights, if any, to technical support or other benefits that may be made available to registered users;

o Responding to your customer service requests, questions and concerns;

o Administering your account registration.

• Processing is necessary to protect the vital interests of the data subject or another natural person:

o Investigating and protecting against intellectual property infringement;

o Confirming the validity of licenses to RetroSkier content;

o Investigating, preventing or taking action regarding violations of our Terms of Service.

• Processing in furtherance of RetroSkier’s legitimate interests:

o Providing, improving and customizing our website and services;

o Administering our operations and meeting our contractual obligations to our customers and contributors;

o Analyzing and understanding how our online platforms are being used;

o Maintaining the security and integrity of our websites and other services;

o Sending you requested product or service information and keeping you informed about special offers and services of RetroSkier and selected third parties;

o Administering promotions and sweepstakes;

o Research and product/service development for the improvement of our Site, services and offerings.

• Processing is necessary for compliance with RetroSkier’s legal obligations, including:

o Investigating and protecting against intellectual property infringement, fraud, spam, harassment, crime and security risks;

o Compliance with money laundering, bribery, corruption, and applicable sanctions laws and regulations; and

o Meeting financial reporting and other obligations under applicable securities laws.

5. Information Sharing with Service Providers / Agents

RetroSkier uses one or more outside credit card processing companies to bill you for our goods and services. To the best of our knowledge, these companies do not retain, share, store or use personally identifiable information for any other purpose.

We also share Personal Information with certain companies that perform services on our behalf. We only share the Personal Information which is necessary for them to perform those services. We require any company with which we may share Personal Information to protect that data in a manner consistent with this policy and to limit the use of such Personal Information to the performance of services for RetroSkier.

We do not sell or otherwise provide Personal Information to other companies for the marketing of their own products or services.

6. Data Retention and Data Portability

We will retain your information for as long as your account is active and your information is needed to provide you services, as necessary to validate or enforce the licenses to use Content, or as required to fulfill our legal obligations.

If you wish to delete your account or request that we no longer use your information please contact privacy@RetroSkier.com. We will respond to your request within 30 days. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

7. Your Choices (Opt Out)

RetroSkier does not sell your personal data or personal information to any third party. We may use third party advertising services to manage the advertisements that we place on other sites. Our third-party partner may use technologies such as cookies and trackers to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by contacting privacy@retroskier.com. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

RetroSkier will only use your personal information for the purposes described in this Privacy Statement and will not use your personal information for a purpose that is materially different without your express authorization.

You may "opt out" of receiving RetroSkier's email updates, newsletters and/or partner emails by contacting privacy@retroskier.com.

8. Protection of Your Personal Information

The Personal Information that you provide in connection with the use of the Site is protected in several ways.

• Access by you to your account profile is available through a password and unique customer ID selected by you. This password is encrypted. You should strive to use a strong, alpha-numeric password which you should not divulge to anyone.

• Your Personal Information resides on secure servers that only selected RetroSkier personnel and contractors have access to via password.

• Your Personal Information is encrypted whenever it is transmitted to RetroSkier.

• When you enter sensitive information (such as credit card number) on our registration or order forms, we encrypt that information using transport layer security technology.

We strive to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we take into account the sensitivity of the Personal Information we collect, process and store, and the current state of technology to use these measures protect your Personal Information, we cannot guarantee its absolute security.

If you have any questions about security on our Web Sites, you can send email to us at privacy@RetroSkier.com.

9. Cookie and Tracking Technologies

The Site may automatically collect information as you browse, such as Internet Service Provider, browser type and version, operating system and device type, average time spent on our site(s), pages viewed, information accessed, the Internet Protocol (IP) address used to connect your computer to the Internet and other relevant statistics. Such information is sometimes referred to as web analytics and/or clickstream data.

We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, and provide site functionality.

Technologies such as: cookies, beacons, tags and scripts are used by RetroSkier and our affiliates, analytics services and service to provide site features and functionality. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

• A cookie is a small, unique text file that a website can send to your computer when you visit a site. We may use session cookies, which terminate when a user closes his or her browser, and/or persistent cookies, which remain on the user's computer until manually deleted. Most web browsers can either alert you to the use of cookies or refuse to accept cookies entirely. If you do not want us to deploy cookies to your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie on your computer. Rejecting cookies may affect your ability to use the Site.

• We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by writing to us at privacy@retroskier.com. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

You can find more information about the cookies and third party advertising partners in our Cookie Statement above.

We enable you to create a profile for accessing blogs or online communities for sharing information such as messages, photos and videos. Please note that we cannot control the actions of others with whom you may choose to share your pages and information. Any information you post to a public bulletin board or chat room, such as the Forum. For Contributors (the "Forums"), is available to all persons accessing that location. To request removal of your personal information from our blog or community forum, contact us at privacy@RetroSkier.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. Alternatively, if you used a third party application to post such information, you can remove it, by either logging into the said application and removing the information or by contacting the appropriate third party application.

Your email address will not automatically be posted on the Forums unless you modify the default setting to permit that. Your email address will then be available to all persons accessing the Forums. In addition, any information that you choose to include in your profile can be viewed by all visitors to the Forums. You can change your profile under your profile setting, if that feature is available.

10. Changes in Privacy Policy

RetroSkier reserves the right to amend the Privacy Policy from time to time at its sole discretion and will provide notice by email or on the home page of the Site when we make material changes to this Privacy Policy prior to the change becoming effective. If as the result of such changes, you want to alter the ways in which RetroSkier, you may do so by changing your data in the Personal Information section, if applicable.

You will be deemed to have been made aware of, and will be subject to, any material changes to the Privacy Policy after such notice has been posted with the following exception: If at the time you provide Personal Information to RetroSkier you are given the opportunity (as you currently are) to limit how such information will be used to communicate with you, either by RetroSkier or by third parties, RetroSkier will not change your preference in this regard without your express consent. However, if RetroSkier is acquired by or merged with another entity, RetroSkier may provide to such entity customer information that is related to that part of our business that was sold to or merged with the other entity without your consent, but RetroSkier will provide notice of such asset sales, acquisitions, or mergers on this Site.

11. Non-Discrimination

RetroSkier will not discriminate against any user who exercises rights under the California Consumer Privacy Act or other privacy or data protection law. We will not deny services from users who exercise rights under a privacy law and we do not charge different prices to users who choose to exercise rights under applicable privacy law.

12. Links to third party sites

Our Site includes links to other Web sites whose privacy practices may differ from those of RetroSkier. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

13. Social Media Widgets

Our Web sites may include Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

14. Single Sign-On

You may be able to log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.

15. Referral Program Emails

If you choose to use our referral service to tell a colleague about our Site, share a Collection, or invite someone to join a team account, we may ask you for your colleague's name and email address. If so, we will automatically send your colleague a one-time email inviting him or her to visit the Site. RetroSkier stores this information for the sole purpose of sending this one-time email, tracking the success of our referral program, and managing access to Collections.

Your colleague may contact privacy@RetroSkier.com to request that we remove this information from our database.

16. Children

We do not intend to solicit or collect Personal Information from anyone under the age of 18. If you are under 18, do not enter information on this site or engage our services. If you believe a child of yours under the age of 18 has entered Personal Information please contact privacy@RetroSkier.com to have the data removed and terminate the child's account.

17. Privacy Complaints

RetroSkier takes its users' privacy concerns seriously. If you believe that RetroSkier has not complied with this Privacy Policy with respect to your Personal Information, or if you have any questions about this Privacy Policy, the practices of this site, or your dealings with this Web site, you can contact us at privacy@RetroSkier.com.