Privacy Policy

I. Introduction and Overview

Thank you for using the Roombox Services! We are committed to providing you the best online shopping and delivery experience possible. This Privacy Policy explains what information we (ROOMBOX LLC) collect, how that information is used, under what circumstances we share information, and the choices you can make about that information. This Privacy Policy applies whether you access the Roombox Services (as defined in the Terms of Service) through a browser, a mobile application, or any other method.

 

This Privacy Policy also describes how we collect, use and disclose your personally identifiable information (“PII”), including personally identifiable health or medical information (“Personal Health Information” or “PHI”). PII is information about you that may be used to identify you (such as your name, phone number, or address). Personal Health Information is PII combined with information that relates to (a) your past, present, or future physical or mental health or condition, (b) the provision of health care to you, or (c) your past, present, or future payment for the provision of health care.

 

II. Information we collect

1. Information you provide to us or allow others to provide to us

At various points in the Roombox experience, you may provide us with information about yourself. For example, when you create an account through the Services, you provide us with personal information like your name, email address, and zip or postal code. And if you place an order through the Services, we collect information including your address, phone number, birth date, driver’s license expiration date (for alcohol orders or prescription delivery, where available), credit card information, vehicle license plate number(s) (for curbside pickup orders) and the details of your order. Your account information may be updated or corrected by accessing your account settings.

 

We may also collect health information you provide directly to us regarding an experience with a retail partner that may require us to contact that retailer, or other retailer partners, for public health or safety reasons, or to facilitate a refund. We do not share your identity with the retailers that we may contact in such a capacity, but may share date, time and location of a transaction, which may allow a retailer to independently identify you.

 

Our partners may let us collect information about use of their sites/apps or share such information with us. For example, if you use an Roombox button or widget on another site or app, we may receive information about your use of that button or widget and the third-party site/app.

 

Location Information:

When you use the Services, we may collect precise location data. For instance, if you allow the Services to access location services through the permission system used by your device’s mobile operating system or browser, we may collect the precise location of your device. We use your location information to facilitate the prompt hand-off of pickup orders (where available), to assist you in finding nearby stores for which pickup or delivery are available, for other similar purposes and for analytics purposes. You can choose whether or not to enable the location tracking feature through the settings on your device or browser, or when prompted by the Roombox mobile app. We may also infer your general location information, for example by using your internet protocol (IP) address.

 

2. Technical information about usage of the Services

When you use the Services, or browse our sites, either through a browser or mobile app, we automatically receive some technical information about the hardware and software that is being used.

 

Cookies, Pixels, and Other Tracking Technologies:

We, our partners, our advertisers, and third-party advertising networks use various technologies to collect information, including but not limited to cookies, pixels, scripts, and device identifiers. Cookies are small text files that are sent by your computer when you access our services through a browser. We, our partners, our advertisers, and third-party advertising networks may use session cookies (which expire when you close your browser), persistent cookies (which only expire when you choose to clear them from your browser), pixels, scripts, and other identifiers to collect information from your browser or device that helps us do things such as understand how you use our services and other services; personalize your experience; measure, manage, and display advertising on the Services or on other services; understand your usage of the Services and other services in order to serve customized ads; and remember that you are logged into the Services. Our partners, advertisers, and third-party advertising networks may use these technologies to collect information about your online activity over time and across different websites or online services. By using your browser settings, you may block cookies or adjust settings for notifications when a cookie is set. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com .

 

 

We employ some third-party services to help us understand the usage of the Services and the performance of advertising, and these third parties may also deploy cookies, pixels, or other identifiers on the Services or collect information through our mobile applications. For example, we use Google Analytics to understand, in a non-personally identifying way, how users interact with various portions of the Services — you can learn more about information that Google may collect here.

 

Log information:

When you use the Services, or browse our sites, our servers will record information about your usage of the Services and information that is sent by your browser or device. Log information can include things like the IP address of your device, information about the browser, operating system and/or app you are using, unique device identifiers, pages that you navigate to and links that you click, searches that you run on the Services, and other ways you interact with the Services. If you are logged into the Services, this information is stored with your account information.

 

3. Children

Our Services are not intended for children under 13 years of age, and we do not knowingly collect personal information (as defined by the U.S. Children’s Online Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 13, we will delete that information to the extent required by applicable laws.

 

We do not knowingly “sell,” as that term is defined under the California Consumer Protect Act (“CCPA”), the personal information of minors under 16 years old who are California residents.

 

III. How we use your information

We may use the information we collect for various purposes, including to:

  • Provide the Services to you, improve the quality of the service, and develop new products and services
  • Allow your Personal Shopper (which means those that shop for and/or deliver the order for you, including our retail partner and their employees/agents where applicable or our third-party providers) to choose your items at a retailer site, deliver your items to you, and/or call or text you with any updates or issues
  • Charge you for the purchase and delivery costs through one or more payment processing partners
  • Offer you customized content (including advertising, coupons, and promotions)
  • Understand how users interact with the Services (including advertising both on and off the Services) as a whole and to test new features or changes in our features
  • Provide customer service, respond to your communications and requests, and contact you about your use of the Services
  • Send you messages related to our community affairs efforts
  • Fulfill any other business or commercial purposes at your direction or with prior notice to you and your consent

You can opt-out of receiving promotional communications from Roombox by using the settings on the Account Info page or by using the unsubscribe mechanism included in the message, where applicable.

 

IV. What we share

The Services comprise a platform that presents you with a set of one or more retailer virtual storefronts from which you can select goods for picking, packing, and delivery by individual Personal Shopper(s) to your location or, if available, for you to pick up in-store. In order to make this work, we need to share information about you and your order with the other parties who help enable the service. This includes, for example, the Personal Shopper(s) who pick and deliver your order, the payment processing partner(s) that we use to validate and charge your credit card, and the retail partner(s) from which you are purchasing goods. To be clear, only our payment processing partner(s) receive credit card information.

We also share information under the following principles:

  • With your consent or at your direction — We will share your information with entities outside of the Services when we have your consent to do so or it is done at your direction. For example:
    • If you enter loyalty card information from a particular retailer, we share that information with the retailer you chose along with your order so that information can be added to your loyalty card account.
    • If you share a recipe publicly on the Services, it is viewable by anyone along with your first name and last initial.
    • If you invite friends to use the Services through our referral program or to share a shopping cart, we will share some information with the friends you invite like your name and picture. Likewise, if you choose to join someone else’s cart, they will see some of your information.
  • With our retail partners — We may share your information with our retail partners in order to provide and maintain the Services.
  • For external processing or service provision — We sometimes share information with third parties to process information on our behalf or to otherwise provide certain services (such as delivery services, advertising services, or information to better tailor our services to you). For the purposes of this processing or provision of services, we may share your information with such third parties under appropriate confidentiality provisions.
  • For legal purposes — We may share your information when we believe that the disclosure is reasonably necessary to (a) comply with applicable laws, regulations, legal process, or requests from law enforcement or regulatory authorities, (b) prevent, detect, or otherwise handle fraud, security, or technical issues, and (c) protect the safety, rights, or property of any person, the public, or Roombox.
  • On a non-personal or aggregate basis — We share information on both a non-personally identifying basis (including, but not limited to, order and delivery details but not including credit card information) or an aggregate basis.
  • To enable purchase of alcohol (not available in all jurisdictions) — When you buy alcohol using the Services, we may be required by law to share certain information with the retailer who makes the sale. This information could include, among other things, the names and addresses of the purchaser and recipient, government issued ID information, the quantity, brand, price, proof, and volume of alcohol purchased, and a recipient signature.
  • For business purposes — We may share your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company. We may also share your information between and among Roombox, and its current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.

 

V. Personal Health Information

This Section (Personal Health Information) governs our use and disclosure of your Personal Health Information. If there is a conflict between the terms of this Section and any other terms of this Privacy Policy or the Roombox Terms of Services, the terms in this Section will govern. To the extent we receive, create, maintain, use or disclose any of your PHI, we will maintain the privacy and security of such information as required by the federal patient privacy law known as the Health Insurance Portability and Accountability Act and the regulations promulgated under that Act (“HIPAA”), as well as any applicable state and other federal privacy policy laws.

 

Your PHI is protected under HIPAA and under certain state laws. Those laws give you rights with respect to the access, use, and disclosure of PHI by your health care providers, such as pharmacies, and us. When you place a pharmacy order using our Services, the pharmacy responds as we have described above under the Section entitled “Information we collect” by disclosing to Roombox your status as a patient of the pharmacy. Information concerning your status as a patient of the pharmacy is PHI and protected by HIPAA. As discussed above, no other PHI will be disclosed to us by your pharmacy and no other PHI will be disclosed by Roombox to your personal shopper other than your status as a patient of the pharmacy. For a more complete description of your rights under HIPAA and the uses and disclosures of your PHI, please refer to your pharmacy’s Notice of Privacy Practices. We will not disclose your PHI without your prior written consent with other people or non-affiliated companies unless: (i) it is needed to provide our Services, (ii) it has been “de-identified” so that it cannot identify you, (ii) we have your prior written consent, (iv) disclosure is required by law, or (v) we are acquired or file for bankruptcy.

 

VI. Security

We employ and maintain reasonable administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorized access, use, and disclosure. In addition, when we collect, maintain, access, use, or disclose your PHI, we will do so using systems and processes consistent with information privacy and security requirements under applicable federal and state laws, including, without limitation, HIPAA. All electronic PHI will be encrypted at rest and in transit. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

We will make any legally required notifications of any breach of the security, confidentiality, or integrity of your PHI or PII, including, without limitation, breaches of your stored PHI or PII (as breaches are defined under applicable state or federal statutes on security breach notification). To the extent permitted by applicable laws, we will make such notifications to you without unreasonable delay, as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

 

VII. Changes to this Policy

This policy may change from time to time and any revised Privacy Policy will be posted at this page, so we encourage you to review it regularly. If we make changes, we will notify you by revising the date at the top of this Privacy Policy and, in the case of materials changes to the Privacy Policy, we may provide you with additional notice (such as a notice in our user interface or sending you a notification by email).

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