Privacy Policy

Last Revised:  August 8, 2024

INTRODUCTION

Your privacy is important to RENFROE, and we are committed to protecting the privacy of all individuals. We provide the website at https://renfroe.kinsta.cloud/ (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:

• the information we collect when you access or use the Website;
• the information we collect from employees and contractors when they use the Portal;
• how we collect the information;
• how we use the information;
• with whom we may share the information;
• where we store the information;
• your rights concerning the information; and
• how you can exercise your rights.

TABLE OF CONTENTS

All capitalized terms in this Policy are defined in the DEFINITIONS section of this Policy.

CONTROLLER

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.

APPLICABILITY OF THIS POLICY

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.

BINDING AGREEMENT

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.

INFORMATION WE COLLECT

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.

HOW WE COLLECT INFORMATION

We collect information:

• Directly from you when you provide it to us.
• Automatically, as you navigate the Website or the Portal. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, such as our business partners.

Information You Provide

You may provide us information in the following ways:

• When you request Services through the Website.
• When you use the Website to communicate with us.
• When you report a problem with our Website.
• When you respond to a survey on our Website.
• When you run searches on our Website.
• When you use the Portal to perform your job.
• When you use the Portal to communicate with us.
• When you report a problem with the Portal.

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.

Information We Collect Automatically

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:

• Details of how you use the Website or the Portal, such as how you access the Website or the Portal, which pages you access, how long you access specific pages, the information you download from the Website, the information you download from or upload to the Portal, and the resources you use on the Website or the Portal.
• Whether or not we have previously connected with you for business development purposes (i.e., do we have a sales lead for you, are you a current customer, or are you in our database for other reasons).
• Information about your computer, such as your operating system, device ID, browsing history, and search history.
• Information about your mobile device, such as your device type, operating system type and version, screen resolution, device language setting, model, manufacturer, mobile carrier, operating system, and other device attributes.
• The different devices you use to access the Website or the Portal.
• Information about your internet connection or the equipment you use to access the internet, such as your IP address.
• The general geographic location of your device (city and state).
• Information about whether you’ve engaged with RENFROE’s brand on social media platforms like Facebook, LinkedIn, and X.
• Derived information reflecting your employer’s name.
• Information about the categories of other websites you have browsed.
• Recordings of your calls to our Home Office team. We use these recordings for quality and training purposes.

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:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your interests.
• Store information about your use of the Portal, allowing us to customize the Portal to improve your ability to do your job.
• Speed up your searches.
• Recognize you when you return to our Website or the Portal.

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).

Information We Collect from Third Parties

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:

• Your name, personal and professional email addresses, and personal and professional phone numbers;
• Profile information, comments, and similar information provided to or on social networks and other forums that connect to us;
• Interests, demographic data, and purchasing behavior; and
• Information collected from you offline or through other channels, such as information you provide when attending an in-person event or function or information you provide to us over the phone.

Information We Do Not Collect

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)).

Information We Collected Between April 1, 2023 and March 31, 2024

Category	Examples	Collected
Identifiers	A 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 identifiers	YES
Personal 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 law	Age (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 information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	NO
Biometric information	Genetic, 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 data	NO
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement	YES
Geolocation data	Physical location or movements	YES
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	NO
Professional or employment-related information	Current or past job history or performance evaluations	NO 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 records	NO
Inferences drawn from other Personal Information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	YES

Collection of Non-Identifiable Information

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.

Your Responsibilities Concerning Information We Collect

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.

HOW WE USE INFORMATION

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:

• Fulfilling your requests;
• Presenting our Website or Portal to you;
• Providing you with the Services you request, view, engage with, or purchase;
• Allowing you to participate in interactive features on our Website and the Portal;
• Providing you with updates about RENFROE’s latest happenings and upcoming events;
• Communicating about your account or transactions with us, including providing you notices about your account;
• Providing you with information about RENFROE, our Services, and our business activities;
• To comply with any applicable healthcare tracing efforts, such as COVID-19;
• For customer service and customer support purposes;
• Sending you information or requesting feedback about features on our Website or the Portal or changes to our policies;
• Sending you offers and promotions for our products and services or third-party products and services;
• Personalizing content and experiences presented to you;
• Providing you with targeted advertising based on your activity on our Website or Portal or third-party sites and applications;
• Providing you with information on our own or third-party products or services based on your activity on our Website or Portal or third-party sites and applications;
• Operating, understanding, optimizing, developing, or improving our Website or Portal, products, services, and operations, including by using guest survey research and analytics tools;
• Displaying advertisements from third parties where it appears that your information matches the target criteria specified by the third party (for this purpose, your information is not shared with or provided to the third party);
• Detecting, investigating, and preventing activities that may violate our policies, pose safety issues, or be fraudulent or illegal;
• Testing, research, analysis, and product development, including development and improvement of our Website and Portal and our Services;
• Notifying you of product recalls or safety issues;
• Fulfilling our obligations or enforcing our rights arising from any contracts entered into between you and us, including for billing and collection;
• To prevent transactional fraud;
• Notifying you about changes to our Website or Portal or any Services we offer or provide;
• Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of RENFROE’s assets if Personal Information about our users is one of the assets being transferred;
• Speeding up your searches;
• Providing, personalizing, measuring, and improving your experience with our Website, Portal and Services and delivering content and Services;
• Estimating our audience size and usage patterns;
• Maintaining and improving the safety, security, and integrity of our Website, Portal and Services;
• Recognizing you when you return to our Website or Portal so that we can return you to where you were on the Website or Portal;
• Supporting our general business operations;
• Providing our contractors and employees with information regarding their employment or contract;
• In any other way we may describe when you provide the information;
• For any other purpose, with your consent; and
• For any other lawful purpose that is our legitimate interest and not overridden by your data privacy rights.

To learn more about how we use your information for personalization and tracking, please see COOKIE POLICY (ONLINE TRACKING TECHNOLOGIES).

Our Legal Basis for Processing Your Data

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 you	Our 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 contractors
Processing 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 control	Our 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 contract
Processing your Personal Information to publish your information on our Website and elsewhere through our Services following your express instructions	Your 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 contract
Processing 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 handling	Our 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 business
Processing 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 business	Your consent; or our legitimate interests, namely, monitoring, supporting, improving, and securing our Website, Portal, Services, and business generally
Processing your personal data to create and maintain our databases, backup copies of our databases, and our business records generally	Our 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 notice
Processing your personal data for security and the prevention of fraud and other criminal activity	Our legitimate interests, namely the protection of our Website, Portal, Services, and business, and the protection of others
Processing your personal data where necessary for obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice	Our legitimate interests, namely the proper protection of our business against risks
Processing 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 procedure	Our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others
Processing 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 person	Our legitimate interests, namely the proper protection of our business against risks

SHARING OR SELLING YOUR INFORMATION

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.

Personal Information

We may share your Personal Information in the following situations:  

• To fulfill the purpose for which you provided it;
• With our affiliates (such as other companies that own us, that we own, or that share common ownership with us);
• When you allow us to share your Personal Information with another company, by electing to share your Personal Information with carefully selected companies so that they can send you offers and promotions about their products and services;
• When you direct us to share your Personal Information with another company to fulfill your request;
• When you direct us to share your Personal Information with third-party sites or platforms, such as social networking sites;
• When we work with clients to identify appropriate employees and contractors to assist them;
• When we cooperate with other businesses to offer co-branded products or services to you, however, we will do so only if permitted by applicable law, and, in these cases, the other business will be prohibited from using your Personal Information for purposes other than those related to the co-branded products or services;
• When companies perform services on our behalf, like package delivery, marketing and advertising, and customer service, however, these companies are prohibited from using your Personal Information for purposes other than those requested by us or required by law;
• When requested by law enforcement agencies, regulators, and courts in response to a court order, subpoena, regulatory requirement, or similar legal process, to report any activities we reasonably believe to be unlawful or as otherwise required by law;
• To combat fraud or criminal activity and to protect our rights, users, and business partners, or as part of a legal proceeding affecting RENFROE;
• When we share your Personal Information with third parties as part of selling the business, to enforce our Terms of Use or rules, to ensure the safety and security of our users and third parties, to protect our rights and property, and the rights and property of our guests and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law;
• When it is necessary to respond to a public health emergency, or in an emergency, to protect the safety of your health and property;
• For any other purpose we disclosed when collecting the information; and
• With your consent.

Aggregated or Non-Identifying Information

We may disclose Aggregated Information or Non-Identifying Information for any reason without restriction.

Information Shared Between April 1, 2023 and March 31, 2024

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
Identifiers	Affiliates, Service Providers, Business Partners, Social Media
California Customer Records Personal Information categories	Affiliates, Service Providers, Business Partners, Social Media
Protected classification characteristics under California or federal law	N/A
Commercial information	Affiliates, Service Providers, Business Partners, Social Media
Biometric information	N/A
Internet or other similar network activity	Affiliates, Service Providers, Business Partners, Social Media
Geolocation data	Affiliates, Service Providers, Business Partners, Social Media
Sensory data	N/A
Professional or employment-related information	Affiliates, Service Providers, Business Partners, Social Media
Non-public education information	N/A
Inferences drawn from other Personal Information	N/A
Log-in, Account, or Financial Card Number, in combination with required Access Code	N/A

YOUR INFORMATION – YOUR CHOICES

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:

The Right to Know/Right To Access

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:

• the categories and specific pieces of Personal Information that we have collected about you in the past 12 months,
• the sources from which we have collected that information,
• our business or commercial purpose for collecting such information,
• the categories and specific pieces of Personal Information that we have disclosed to third parties for a business purpose during the past twelve months,
• the categories and specific pieces of Personal Information that we have sold to third parties during the past twelve months, and
• the third parties to whom we have disclosed or sold such Personal Information.

In most cases, you may request this information up to two times each year.

The Right to Data Portability

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.

The Right to Correct/Right to Rectification

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.

The Right to Delete/Right to Erasure

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:

1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted under federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with any international, national, federal, state, or local laws, rules, or regulations applicable to us or your Personal Information.
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of Promotional Offers

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.

Right to Opt-Out of Targeted Advertising and Profiling

RENFROE does not use targeted advertising or engage in profiling.

Right to Opt-Out of Sale or Sharing of Personal Information

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:

• Do Not Sell or Share My Personal Information
• Click on the link “DO NOT SELL OR SHARE MY PERSONAL INFORMATION” on the footer of our Website.
• Enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt-out. 
• Submit a request to us by emailing legal@earenfroe.com.

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.

EXERCISING YOUR RIGHTS

To exercise any of your rights, submit a request to:

• RENFROE
  Attn:  Legal
  1800 International Park Drive
  Suite 250
  Birmingham, AL 35243
• Telephone: 205-982-6230
• Legal@earenfroe.com

When submitting a request, you must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of such individual.
• Describe your request with sufficient detail that allows us to understand, evaluate, and respond to it properly.

VERIFICATION OF REQUESTS

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.

Verifying an Authorized Agent

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:

• For requests to know and delete: (1) providing a valid power of attorney under the laws of the subject individual’s state of residence; or (2) providing sufficient evidence to show that the subject consumer has (i) provided the Authorized Agent signed permission to act on their behalf, (ii) verified their own identity directly with us, and (iii) directly confirmed with us that they have provided the Authorized Agent permission to submit the request on their behalf; and
• For requests to opt-out: submitting a signed permission demonstrating that the subject consumer has authorized the Authorized Agent to act on their behalf.

RESPONDING TO YOUR REQUEST

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.

APPEAL PROCESS

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.

NON-DISCRIMINATION FOR EXERCISING YOUR RIGHTS

We will not discriminate against you for exercising any of your data protection rights, and specifically, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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.

CHILDREN’S PRIVACY POLICY AND PRACTICES

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.

DATA SECURITY, RETENTION POLICIES AND PRACTICES

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. 

GLOBAL DATA TRANSFER, STORAGE, AND PROCESSING PRACTICES

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.

UPDATES TO THIS PRIVACY POLICY

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.

CONTACT INFORMATION

If you have a comment or question about this Policy, please contact us at: 

• RENFROE
  Attn:  Legal Department
  1800 International Park Drive
  Suite 250
  Birmingham, AL 35243
• Telephone: 205-982-6230
• Legal@earenfroe.com

DEFINITIONS

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://renfroe.kinsta.cloud/.

JURISDICTION SPECIFIC RIGHTS

UNITED STATES

California

California residents have the following rights:

Shine the Light Act

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 

Request to Know

Received: 0

Request to Delete

Received: 0

Do Not Sell My Personal Information Requests:

Received: 0

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

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.

European Economic Area (GDPR – EEA) and United Kingdom (GDPR UK)

• When you access or use our Website or Portal, your personal data is controlled by RENFROE. We are a Controller as defined in GDPR.
• Right to Delete: 
  • You have the right to request that we delete Personal Information you provided or was collected about you, subject to applicable legal exceptions. See Right to Delete/Right to Erasure.
  • For EU and UK residents, we may deny your request for deletion if the information is necessary to:
    • Complete the transaction for which we collected the Personal Information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;Comply with a legal obligation; or
    • Make other internal, lawful, and legitimate uses of that information that are compatible with the context in which you provided it and are not overridden by your data privacy rights.
• Right to Revoke Your Consent: You have the right to withdraw your consent to the Processing of your Personal Information without detriment at any time where we rely on consent as the lawful basis for Processing your Personal Information.
• Right to Limit Processing of Your Data:  You have the right to restrict Processing of your Personal Information where, for example, the information is inaccurate or it is no longer necessary for us to Process such information or where you have exercised your right to object to our Processing.
• You have a right to lodge a complaint with your local Data Protection Supervisory Authority or the UK Information Commissioner’s Office: https://ico.org.uk/for-the-public.

COOKIE POLICY (ONLINE TRACKING TECHNOLOGIES)

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.

TYPES OF COOKIES

• Cookies. Cookies are small data files created by web browsers and downloaded onto your computer or other device when you access a website. Cookies help make your browsing experience with our Website and Portal more personal. Different cookies serve different purposes, such as recognizing your devices, storing information about your preferences, identifying the geographic area of a user, tracking browsing habits and preferences, and recalling information entered on forms, login pages, or other features of the Website. This helps us understand how the Website is being used and is used to improve your browsing experience on the Website generally.
• Session Cookies expire once you close your web browser. Persistent Cookies stay on your computer or mobile device until you delete them. For information on cookies that RENFROE uses, please see What Cookies Do We Use?.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Website that collects information about users’ engagement on the site. We may use pixels to record, for example, that a user has visited a particular web page.
• Tracking/Marketing/Advertising Cookies. Tracking/Marketing/Advertising cookies track your online activity to help advertisers deliver more relevant advertising or limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and usually originate with third parties. You can opt out of almost all these cookies by updating your preferences on www.aboutads.info.
• Analytics Cookies. Google Analytics 4 and Google Ads collect visitor behavior and demographic information for our Website. For more information on how Google uses your information, please see Google’s Privacy Policy at https://policies.google.com/privacy?hl=en-US and Google’s Advertising Policy at https://policies.google.com/technologies/ads?hl=en-US.
• Social Media Cookies. Social media cookies are stored on your computer browser to help you log into your social media accounts faster. Social media companies may recognize you and collect information about your visit to our Website or Portal, and they may set a cookie or employ other tracking technologies. The privacy policies of those companies govern your interactions with those features.

CATEGORIES OF COOKIES

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 Cookies	These 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 Cookies	These 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 Cookies	These cookies are used to track visitors across Websites and allow publishers to display relevant and engaging advertisements.
Statistics Cookies	These cookies are used to generate statistical reports and heat maps providing information on the use of different aspects of the Website.

What Cookies Do We Use?

RENFROE uses first and third party cookies that are classified as essential, preference, marketing, analytics, and statistics cookies. Specifically, RENFROE uses the following Cookies:

WHY DO WE USE 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.

HOW DO THIRD PARTIES USE COOKIES ON OUR WEBSITE?

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.

HOW YOU CAN CONTROL COOKIES?

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.