VIRGINIA NOTICE DISCLOSURES FOR VIRGINIA RESIDENTS

The following additional disclosures apply to Virginia residents in accordance with applicable Virginia law, including the Consumer Data Protection Act, as amended from time to time (hereinafter “VCDPA”).  This notice supplements the general Privacy Notice found here [LINK].  Any capitalized but undefined terms shall have the meanings set forth in the general Privacy Notice.

Targeted Advertising and Opt-Out Rights

Our use of tracking technology, including cookies and related technology, may be targeted advertising under the VCDPA.  If you would like to opt out of this advertising you may click “Do Not Sell Or Share My Personal Information” [LINK] (also found at the bottom of the page), or you may broadcast the Global Privacy Control signal (which can be found at https://globalprivacycontrol.org/). 

Other Rights and Choices of Virginia Residents

The VCDPA also provides Virginia residents with specific rights regarding their personal data.  This section describes the rights of Virginia residents under the VCDPA, and explains how to exercise those rights.

1. Access Rights

Virginia residents have the right to request that we disclose certain information to you about our collection and use of your personal data.  You may request (see Exercising Rights) the following:

• Confirmation whether or not we are processing your personal data .
• Access your personal data that we process.

Once we receive and confirm a Virginia resident’s verifiable consumer request (see Exercising Rights), we will provide confirmation/access to the applicable personal data.  Please also see Data Portability Rights for how we may provide information.  

1. Deletion Rights

Virginia residents have the right to request that we delete any of their personal data that we collected from or obtained about Virginia residents, subject to certain exceptions.  Once we receive and confirm a Virginia resident’s verifiable consumer request (see Exercising Rights), we will delete (and direct our service providers to delete) his/her personal data from our records.

1. Data Correction Rights

Virginia residents have the right to request that we correct inaccuracies in their personal data, considering the nature of the personal data and the purposes of the processing of the personal data.  Once we receive and confirm your verifiable consumer request (see Exercising Rights), we will use commercially reasonable efforts to correct the inaccurate personal data.

1. Data Portability Right

Virginia residents have a right to request that we provide a portable copy of the personal data that the Virginia consumer previously provided to us.  Once we receive and confirm a verifiable consumer request (see Exercising Rights), we will provide a copy of your personal data.  Subject to certain restrictions, you may also request that the data be provided in a format that allows transfer to another business. 

Exercising Rights

To exercise the rights described above, please submit a verifiable consumer request to us by:

• Calling us at (855) 996-3746;
• Emailing us at help@royalrobbins.com; or
• Submitting a request by mail to:

Royal Robbins LLC
Attn: Privacy Compliance Officer
575 Sutter Street
San Francisco, CA 94102

Only Virginia may make a verifiable consumer request related to a Virginia resident’s personal data.  A Virginia resident may also make a verifiable consumer request on behalf of his/her minor child. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify that the Virginia resident is the person about whom we collected personal data or an authorized representative.
• Describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide a Virginia resident with personal data if we cannot verify his/her identity or authority to make the request and confirm the personal data relates to that Virginia resident.

Making a verifiable consumer request does not require a Virginia resident to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the personal data requested.

Initial Request Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (for a maximum total of 90 days), we will notify the Virginia resident. Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide the Virginia resident personal data that is readily useable and should allow him/her to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to a Virginia resident’s verifiable consumer request unless the request is excessive or manifestly unfounded.  If we determine that the request warrants a fee, we will tell the Virginia resident why we made that decision and provide him/her with a cost estimate before completing the request.  Alternatively, we may decline to respond to the request and notify the Virginia resident of our reason for doing so.

Appeals Response Timing and Format

If we decide that we cannot comply with a Virginia resident’s initial request, that Virginia resident has a right to appeal our decision.  Any appeal should be sent to the place where the initial request was sent (see Exercising Rights).  The appeal should clearly indicate that it is an appeal of an initial request and should include the initial request along with our response explaining why we cannot comply with the request.  We will review all appeals and provide a response, including the reasons we cannot comply with the request, if applicable.  If we cannot comply with a request after an appeal is made, Virginia residents may submit a complaint to the Virginia Attorney General, which can be found here.

Non-Discrimination

We will not process Virginia residents’ personal data in violation of state and federal laws that prohibit unlawful discrimination against Virginia residents.  We will also not discriminate against a Virginia resident for exercising any of his/her VCDPA rights.  Unless permitted by the VCDPA, we will not:

• Deny a Virginia resident goods or services.
• Charge a Virginia resident different prices or rates for goods or services.
• Provide a Virginia resident a different level or quality of goods or services, including denial of goods or services.