Effective Date: May 14th 2021
Overview and Scope
This Policy applies to the Apollo Retail Specialists, LLC Sites, which includes bdsmktg.com, wowbrands.com, themagexperience.com, apolloretail.com, their subdomains, and all of the websites and internet properties owned or operated by us, regardless of the medium by which the Sites are accessed by Users (e.g., via a web or mobile browser).
Information We Collect
We are the sole owner of information collected on the Sites. We collect several types of information from and about Users of the Sites, including:
Personal Information: We may collect PII from you when you complete forms, navigate web pages, and in connection with other activities, services, features, or resources we make available on the Sites. The type of PII we may collect, use, store, and disclose include the following: First Name, Last Name, Company/Employer, Email, Mailing Address, Phone Number, IP Address etc. We also collect the following information provided by you for the purpose of applying for career opportunities with us: First Name, Last Name, Email, Phone Number, Education History, Work History, and anything else you provide.
De-identified Information: We may collect de-identified information from you that may not by itself reasonably identify you as the source when you navigate the Sites (“De-identified Information”). De-identified Information may include: (i) device type, (ii) device operating system, (iii) internet browser type, (iv) internet service provider, (v) referring/exit pages, (vi) date/time stamp, and (vii) clickstream information. We will take reasonable measures to ensure that De-identified Information we collect is not personally identifiable and may not later be easily used to identify you as required by applicable law.
We do not offer our services or promote the Sites to, nor do we intentionally collect or retain PII from, children who are younger than 18 years of age. If we discover that we have inadvertently collected information from a child under 18 years of age, we will promptly take all reasonable measures to delete such information from our systems.
How We Collect Information
The information we collect depends on what Users do when they visit or utilize the Sites. We collect PII and De-identified Information in various ways, including:
Directly from You: We collect PII when you voluntarily submit PII to us while completing forms on the Sites and in connection with other activities, services, features, or resources we make available on the Sites. The PII we collect depends on what you do when you visit or utilize the Sites or how you choose to communicate with us. Please note that we do not collect PII about you unless you voluntary provide such PII by completing forms available on the Sites and/or contacting us regarding the Sites or our products and services.
Through Your Use of the Sites: We may collect PII and De-identified Information that your browser transmits when you visit the Sites. We may also collect De-identified Information about how you access and interact with the Sites through the use of automated tracking technologies, such as session cookies, persistent cookies, and web beacons.
A cookie is a small data file that is transferred to an internet browser, which enables the Sites to remember and customize your subsequent visits. We may use session cookies to make it easier for you to navigate the Sites. In particular, we may use session cookies to record session information, such as which web pages you visited and to track your activity on the Sites. Session cookies expire when you close your browser. We may also use persistent cookies to track and target your interests to enhance your experience on the Sites. Persistent cookies remain on your device for an extended period of time.
Most internet browsers automatically accept cookies. However, you can instruct your internet browser to block cookies or to provide you with a warning prompt before you accept cookies from the Sites. Please refer to your internet browser’s instructions to learn more about these functions. If you reject cookies, the functionality of the Sites may be limited and you may not be able to participate in several of the Sites’ features.
Additionally, we may use web beacons, which are single-pixel, electronic images embedded in the Sites that allow us to gather information about your browsing activities on the Sites.
How We Use Information
We may use Users’ PII for various general lawful purposes for which you specifically provided the information including:
Direct Marketing: We may use your PII to send you promotional materials. You have the right to opt-out of receiving direct marketing.
Customer Service and User Communications: We may use your PII to help us respond to your inquiries, questions, requests, and support needs more efficiently.
User Experience Personalization: We may use Users’ PII and/or De-identified Information in the aggregate to analyze Users’ browsing and usage activities and patterns in order to understand Users’ interests and preferences with respect to the Sites and our services. This will help us optimize your experience on the Sites.
Business Optimization: We may use your PII and/or De-identified Information to improve the content on our web pages, to customize the content and layout of our web pages, and in managing our everyday business needs. We may also use your feedback to improve the Sites and our services. All of this is done with the intention of making the Sites more useful for you.
We will not collect additional categories of PII or use PII we collected for materially different, unrelated, or incompatible purposes without providing you notice.
How We Disclose Information
We may disclose Users’ PII to third parties for a business purpose as described below. Otherwise, we do not sell PII and will not disclose Users’ PII to third parties without your permission.
To Our Affiliates: We may disclose your PII to affiliates, including companies within the Apollo Retail Specialists.
To Service Providers: We may disclose your PII to third party service providers that assist us in providing user support, communicating with Users, and promoting our services, as well as third party service providers that provide other services to us relating to our services and/or the Sites.
Sale or Acquisition of Assets: If we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, or if we are transferred to another company, we may disclose and/or transfer your PII as part of the transaction. If the surviving entity in that transaction is not us, the surviving company may use your PII pursuant to its own privacy policies, and those policies may be different from this Policy.
PII We Sold or Disclosed for a Business Purpose: In the preceding 12 months, we have not sold any PII that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
In the preceding 12 months, we have disclosed for a business purpose to one or more service providers and third parties the following categories of PII that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Identifiers (e.g., a name, alias, postal address, email address, account name);
Internet or other electronic network activity information (e.g., information regarding a with our Sites, and/or advertising);
Professional or employment-related information; and
We only allow our service providers and third parties to handle your PII if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
Law Enforcement, Safety, and Legal Processes: We may disclose your PII to law enforcement or other government officials if it relates to a criminal investigation or alleged criminal activity. We may also disclose your PII: (i) if required or permitted to do so by law; (ii) for fraud protection and credit risk reduction purposes; (iii) in the good-faith belief that such action is necessary to protect our rights, interests, or property; (iv) in the good-faith belief that such action is necessary to protect your safety or the safety of others; or (v) to comply with a judicial proceeding, court order, subpoena, or other similar legal or administrative process.
The security and confidentiality of your PII is very important to us. We use commercially reasonable security measures to protect your PII on the Sites. However, no data transmitted over or accessible through the internet can be guaranteed to be 100% secure. As a result, while we attempt to protect your PII, we cannot guarantee or warrant that your PII will be completely secure (i) from misappropriation by hackers or from other nefarious or criminal activities, or (ii) in the event of a failure of computer hardware, software, or a telecommunications networks.
California Privacy Rights
California’s “Shine the Light” law permits Users of the Sites that are California residents to request certain information regarding our disclosure of PII to third parties for their direct marketing purposes.
Under the California Consumer Privacy Act (“CCPA”) signed into law June 28, 2018 and entering into effect Jan. 1, 2020, California residents have certain rights and privileges. These rights include the:
Right to Know: the right to request disclosure of PII collected or sold.
Right to Deletion: the right to request deletion of PII collected from you from our records and from our service providers’ records.
*“Do Not Sell Right”: the right to opt-out of the sale of PII (if applicable).
Right to Sue for Security Breaches.
Protection Against Discrimination because you exercised any of your rights under CCPA.
*We do not sell your PII to third parties and have no plans to do so in the future.
We reserve the right to ask for information verifying your identity and residency prior to disclosing any information to you or acting on your request. Should we ask for verification, the information you provide to verify your identity and residency will be used only for that purpose, and all copies of this information in our possession will be destroyed when the process is complete. We strive to respond to your request within 45 days of receiving a verifiable consumer request however, we reserve the right to respond within 90 days when reasonably necessary.
To make a request under this section, please contact us at the Contact Information provided below.
Do Not Track Disclosure
Some internet browsers may transmit “do-not-track” signals to websites with which the browser communicates. The Sites currently respond to these “do-not-track” signals.
We do not participate in bulk email solicitations that you have not consented to receiving (i.e., “Spam”). We do not sell or disclose customer lists or email address lists to unrelated third parties. Except as otherwise provided herein, we do not share PII with any third party advertisers.
Third Party Links
The Sites may contain links to other websites or applications (“Linked Sites”) that are not owned by us. We do not control the collection or use of any information, including PII, which occurs while you visit Linked Sites. Therefore, we make no representations or warranties for—and will not in any way be liable for—any content, products, services, software, or other materials available on Linked Sites, even if one or more pages of the Linked Sites are framed within a page of the Sites.
Furthermore, we make no representations or warranties about the privacy policies or practices of the Linked Sites, and we are not responsible for the privacy practices of those Linked Sites. We encourage you to be aware of when you leave the Sites and read the privacy policies of Linked Sites.
Accessing, Updating, and Controlling Information
If you ever wish to access, update, change, or delete your PII, or cancel your user account (if applicable), you may do so by contacting us at the Contact Information provided below. To help us process your request, please provide sufficient information to allow us to identify you in our records. We reserve the right to ask for additional information verifying your identity prior to disclosing any PII to you. Should we ask for verification, the information you provide will be used only for verification purposes, and all copies of the information will be destroyed when the process is complete.
If you do not wish to receive update messages and/or direct marketing communications from us, you may opt-out by following any instructions included in the communication or by contacting us at the Contact Information provided below. To help us process your request, please include sufficient information for us to identify you in our records. Please be aware that although you may opt-out of update messages and/or direct marketing communications, we reserve the right to email you administrative notices regarding the Sites, as permitted under the CAN-SPAM Act.
We will make commercially reasonable efforts to respond to opt-out requests, account cancellation requests (if applicable), and handle requests to access, update, change, or delete PII as quickly as possible.
If you have questions about this Policy or need extra help reading the policy, would like to exercise the aforementioned consumer rights, or wish to contact us with questions or comments, please contact us at:
Apollo Retail Specialists, LLC
4450 E. Adamo Dr. #501, Tampa, FL 33605
CCPA technically requires BDS to provide a policy that governs offline data collection too however, based on the responses provided we left this as online only because BDS only collects PII through the website form and career website iCIMS.
CCPA requires that the policy disclose whether or not personal information is “sold” (under CCPA’s broad definition of sale which would include information disclosed in exchange for “anything of value” absent a written contract that use the appropriate language under the CCPA’s definitions. Based on the responses provided we noted that BDS has not sold any PII but we may want to revisit vendor agreements to close the loop here.