California: If your RMI account has a California mailing address, we will not share personal information we collect about you except to the extent permitted under California law.

This Privacy Policy describes the privacy practices of Robert Madden Industries, Ltd. (“RMI”) and its respective affiliates (collectively, “Madden,” “we,” “us,” or “our”) and how we handle personal information that we collect through our digital properties that link to this Privacy Policy, including our website, mobile application, and browser extensions (collectively, the “RMI Website”), as well as through social media, our marketing activities, our live events, and other activities described in this Privacy Policy.

If you have registered for a Madden account or we have otherwise obtained your personal information in connection with providing our services, please see our Madden Privacy Notice, which applies to our practices subject to certain financial privacy laws.

California Residents: See the California privacy notice below for important information about our collection, use, and disclosure of your personal information as well as your California privacy rights.

Nevada Residents: See the Nevada privacy notice below for important information about your Nevada privacy rights.

Information you provide to us. Personal information you may provide to us through the RMI Website or otherwise includes:

• Contact data, such as your first and last name, email address, billing and mailing addresses, and phone number.
• Government identifiers, such as national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card.
• Profile data, such as the username, account number, and password for your Madden account, date of birth, gender, education, employment details, biographical details, US residency/citizenship status, income, net worth, preferences, financial experience, information about your participation in our surveys, and any other information that you add to your account profile.
• Billing data, such as the payment card or bank account numbers that you use to make payments or transfers through the RMI Website.
• Financial data, such as information about your financial history that you provide through the RMI Website and the information you authorize us to collect from the financial accounts that you connect to the RMI Website.
• Transactional data, such as information relating to or needed to complete your orders on or through the RMI Website, including transaction history.
• Communications that we exchange with you, including when you contact us with questions or feedback, through the RMI Website (including chat and other interactive features), social media, survey participation, or otherwise.
• Marketing data, such as data you provide when participating in our promotions or in response to our ads or marketing messages.

We may also collect personal information not specifically listed above, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Your financial accounts, such as your bank and credit cards, when you authorize us to collect your information from them.
• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Data providers, such as information services and data licensors that provide demographic and other information.
• Marketing partners, such as joint marketing partners and event co-sponsors.

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the RMI Website, our communications, and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, Bluetooth, LTE, 3G), and general location information that can be inferred from the foregoing, such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the RMI Website, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened or forwarded our emails or clicked links within them.
• Precise location data when you authorize the RMI Website to access your device’s location.

The RMI Website employs the following technologies, which facilitate some of the automatic collection described above:

• Cookies, which are files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser. The RMI Website employs both session cookies that expire when you close your browser and persistent cookies that remain stored on your device. Some of the cookies on our services allow third parties like our service providers and advertising partners to collect data needed for the services they provide to us. The RMI Website employs cookies for the following purposes:
  • Technical operation. To allow the technical operation of the RMI Website, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the RMI Website.
  • Functionality. To enhance the performance and functionality of our services.
  • Analytics. To help us understand user activity on the RMI Website, including which pages are most and least visited and how visitors move around the RMI Website, as well as user interactions with our emails.

You can learn about blocking cookies in the Your choices section below.

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Mobile Application Software Development Kits (SDKs). We may use SDKs in our mobile applications. A SDK is third-party computer code that we or our third party service providers or partners may use for a variety of purposes, including to provide us with analytics regarding the use of our mobile applications, to integrate with social media, add features or functionality to our app, or to facilitate online advertising.

We may use your personal information for the following purposes or as otherwise described at the time of collection:

We may use your personal information to:

• provide, operate, and improve the RMI Website and our business;
• fulfill your requests for products and services;
• communicate with you about the RMI Website, including by communicating with you through sending announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the RMI Website and our communications; and
• troubleshoot and provide support for the RMI Website, and respond to your requests, questions and feedback.

We, our service providers, and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications, including through text message or email. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Interest-based advertising. We may engage third-party advertising companies that use cookies and other technologies to collect information about your interaction (including the data described in the automatic data collection section above) over time across the RMI Website, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share users’ contact data with these companies to facilitate interest-based advertising to those or similar users on other online platforms.

You can learn more about your choices for limiting interest-based advertising in the Your choices section below.

• Promotions. We use personal information to provide the promotional programs that we offer. We may provide these programs in collaboration with affiliate brand partners and other businesses, websites, mobile applications, or third parties. Each such program will be subject to and governed by our Terms of Use, this Privacy Policy, and any other applicable rules or terms and conditions that we or the relevant third parties may post or make available to you.

We may use your personal information for research and development purposes, including to analyze and improve the RMI Website and our business. We may create anonymous, aggregated, or deidentified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated, or deidentified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated, or deidentified data and share it with third parties for our lawful business purposes, including to analyze and improve the RMI Website and promote our business.

We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the RMI Website; and
• prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including fraud, cyberattacks, and identity theft.

The length of time we retain particular categories of personal information is determined based on whether it is sufficient to fulfill the purposes for which we collected it, including to satisfy legal, regulatory, accounting, or reporting requirements, establish or defend legal claims, enforce our agreements, resolve disputes, or fraud prevention.

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

RMI Website providers. Third parties that provide services on our behalf or help us operate the RMI Website or our business (such as mail delivery, hosting, information technology, chat feature support, customer support, email delivery, text message delivery, marketing, consumer research, and website analytics).

Financial institutions. Madden uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the RMI Website, you grant Madden and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy. Madden also uses financial institutions to process your ACH funds transfers from your funding source bank account to Madden for use of the RMI Website.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Affiliate brand partners. When you make a purchase on one of our affiliate brand partner sites, we may share information about you with those affiliate brand partners to operate the relevant promotional program, for example, so that we can credit your account with any earned rewards.

Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with affiliate brand partners or other third-parties with whom we are collaborating in our promotional programs or to offer you additional services. We will share personal information that is needed for these other companies to make the promotion available, provide the services that you have requested and track participation in the promotion or service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Parties (and their advisors) to business transactions or proposed transactions involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Madden or our affiliates (including, in connection with insolvency, bankruptcy, or similar proceedings).

In this section, we describe the rights and choices available to all users. California residents can find additional information about their rights here and Nevada residents can find additional information here.

Access or update your information. If you have an Madden account, you can review and update information in your account settings.

You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP.

You can disable our access to your device’s precise geolocation in your mobile device settings.

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, our websites may not work properly. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. To opt-out of data collection through our analytics provider, Google Analytics, visit www.tools.google.com/dlpage/gaoptout.

Most browsers offer settings that allow you to configure your device to prevent images that would include web beacons/clear GIFs from loading.

Steps you can take to opt-out out of use of your personal information for interest-based advertising include:

• Browser settings. Blocking third-party cookies in your browser settings.
• Privacy browsers/plug-ins. Using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies.
• Platform settings. Using Google’s and Facebook’s opt-out tools to opt-out of their use of your information for interest based advertising:
  • Google: www.adssettings.google.com
  • Facebook: www.facebook.com/about/ads
• Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
  • Network Advertising Initiative: networkadvertising.org/managing/opt_out.asp
  • Digital Advertising Alliance: optout.aboutads.info.
  • AppChoices mobile app, available at www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.

You will need to apply these opt-out settings on each device and browser from which you wish to opt-out. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the ad industry opt-out mechanisms that we linked to above.

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals except where we expressly indicate otherwise. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

To request that we close your RMI Website account or delete your personal information associated with your account, please contact us to request account closure. Certain personal information associated with your account may be retained after account closure in accordance with our data retention policies where required or permitted by applicable law.

The RMI Website may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

We employ, test, and regularly re-evaluate reasonable technical, organizational, and physical safeguards designed to protect the confidentiality, integrity, and security of the personal information we collect, both when we receive it and during transit, such as by encrypting credit card numbers and other sensitive personal information that you enter into the RMI Website. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

The RMI Website is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the RMI Website from a child under 18 in a manner prohibited by law, we will comply with legal requirements to delete it. We encourage parents or guardians with concerns to contact us.

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)), other than the personal information we collect in connection with providing financial products and services.

Depending on how you interact with our website and services, in the preceding 12 months, we may have collected the following categories of personal information about you, in addition to the information we collect in connection with providing financial products and services:

• Identifiers, such as your name and contact information, IP address, and mobile device identifiers
• Commercial information such as purchase history
• Internet usage information, such as browsing history, access history, and use and interaction with our website.

In the preceding 12 months, we have used and disclosed this information for the purposes and to the categories of third parties described above.

If you are a California resident, you may have certain rights. California law may permit you to request that we:

• Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
• Provide access to and/or a copy of certain information we hold about you.
• Delete certain information we have about you.
• Opt you out of the sale of your personal information. As noted below, we do not “sell” your personal information, as that term is defined by the CCPA.

You may have the right to receive information about the financial incentives that we offer to you for your personal information (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the RMI Website to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the RMI Website.

To exercise your rights, please send us an email at websitesupport@rmadden.com or send us a letter to Robert Madden Industries, Ltd., 6021 43rd Street, Lubbock, Texas 79407. You will need to provide additional information to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

The CCPA sets forth certain obligations for businesses that “sell” personal information. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past twelve months. We share certain information as set forth in the Information Use and Sharing section, above, and allow our service providers to collect certain information about your activity, for example through cookies as explained in Cookies / Tracking Technologies section, above.

California Shine the Light Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes within the meaning of that law.

Certain Nevada consumers may opt out of the sale of “personally identifiable information” for “monetary consideration,” as defined under Nevada law, to a person for that person to license or sell such information to others. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any future sales under Nevada law by contacting us as detailed in the “Contact Us” section below. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the RMI Website. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the RMI Website. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the RMI Website after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.