Privacy Policy  

This Privacy Policy describes how realpio.com (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit the Site. When it comes to your personal information, we believe in transparency, not surprises. That’s why we’ve set out here what personal information we collect, what we do with it and your choices and rights.

Collecting Personal Information

When you visit the Site, we collect certain information about your device and your interaction with the Site. We may also collect additional information if you contact us for customer support or inquiries. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

Device information

  • Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.

  • Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.

  • Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.

  • Disclosure for a business purpose: shared with our processor Squarespace.

User information and Outreach 

  • Examples of personal information: Your email address and other details such as your name, address, phone number. 

  • Purpose of collection: to provide customer outreach or general communications with you via email, send you our newsletter per the preferences of your subscription or send you emails about services, events, or other relevant information using the email address you provide us. 

  • Source of collection: collected from you.

  • Disclosure for a business purpose: shared with our processor Squarespace and retained for internal record keeping.

Minors

The Site is not intended for individuals under the age of thirteen. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

We are committed to protecting the privacy and rights of children online. We believe that children should be able to use the Internet in a safe, productive, and efficient manner and should be afforded the highest protection available with respect to their personal information. The Children’s Online Privacy Protection Act (“COPPA“) took effect on April 21, 2000 and imposes certain requirements on web sites directed toward children under 13 that collect information on those children, or on web that know they are collecting information on children under the age of 13. It is our policy not to collect personal information on any person under 13. If you are under the age of 13, you cannot become a registered user of our Sites, or use any service on our Sites that asks for personal information. Our Sites are not

designed for children. If you register with us and we discover that you are under 13, we will delete your registration. We will send you a message if we do this. This policy is designed to protect children. Federal law requires us to take special steps to safeguard children’s privacy. To learn more about COPPA, consult the Federal Trade Commission’s COPPA web site www.ftc.gov or you may call 202/FTC-HELP.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:

  • We use Squarespace to power our website. You can read more about how Squarespace uses your Personal Information here: www.squarespace.com/privacy 

  • We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

  • We may share information internally with our team and company or third parties including business partners, independent contractors for the performance of their contract in the normal course of business, and in the event we sell our business.

  • We will not sell, dis or lease your personal information to third parties. 

Behavioural Advertising and Analytics

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. 

For example:

  • We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

  • Analytics assists us in improvement and optimization of our Site.

  • We share information about your use of the Site and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

  • We utilize  the following advertising services: Google, Facebook, Instagram.

  • For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Using Personal Information

We use your personal Information to provide our services to you, which includes keeping you up to date on new services and partnerships that we are launching, conducting surveys or market research. 

Lawful Basis 

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

  • Your consent;

  • The performance of the contract between you and the Site;

  • Compliance with our legal obligations;

  • To protect your vital interests;

  • To perform a task carried out in the public interest;

  • For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you sign up through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We DO NOT engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.
Our processor Squarespace uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Your rights

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the following contact information: info@realbrandstrategy.com.

Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States.  

CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below 

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below:

REAL Brand Strategy 
110 East 25th Street 
New York, NY 10010

Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

We use cookies to optimize your experience on our Site and to provide our services.

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Contact

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at info@activecashmere.com or by mail using the details provided below:

REAL Brand Strategy 
110 East 25th Street 
New York, NY 10010

Last updated: Jul 14, 2021

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: https://ico.org.uk/make-a-complaint/