Privacy
At Berlin Rosen Ltd. (also referred to as “us” or “we”), your privacy is important. This Privacy Policy (the “Policy”) discloses the privacy practices of our website [www.berlinrosen.com] (the “Site”), as well as related products and services we may offer to you (collectively referred to as the “Services”). This Policy covers how we use or share Personal Data that we collect. By using our Site and Services, you agree to the terms of this Policy as they may be amended from time to time.
What Categories of Personal Data Do We Collect, and How Do We Obtain the Personal Data?
We treat data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household as “Personal Data.” Data that has been de-identified or aggregated so that it cannot reasonably be linked to you is not Personal Data, and we may use de-identified data for any purpose.
We may collect the following categories of Personal Data about you:
What Are Our Business or Commercial Purposes for Using Your Personal Data, and With Whom Do We Share Your Personal Data?
We may use or share your Personal Data as follows:
In addition, where consistent with applicable laws, we may use or disclose the above categories of Personal Data:
We take reasonable steps to ensure that service providers to whom we share your Personal Data are contractually obligated to keep the data that we provide to them confidential and to use such information only as we permit.
We do not sell your Personal Data or share your Personal Data for targeted advertising.
Data Retention
We store the information we collect about you for as long as is necessary for the business or commercial purpose(s) for which we collected it or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
Use and Disclosure of Sensitive Information
We do not use or disclose sensitive personal information for any purposes that would require a consumer to exercise a right to limit according to California law.
Use of Cookies
Like many commercial websites, we analyze how visitors use our Site with “cookie” technology. A cookie is a small text file that is placed on your computer when you access the Sites and allows us to recognize you each time you visit the Site. We may use cookies to (1) enhance or personalize your usage and experience on the Site; (2) monitor usage of the Site; and (3) improve the Site and our Services.. We may work with service providers or third parties that help us track, collect and analyze this information. We may combine the information we collect through cookies with other information we have collected from you or information from other sources.
Most browsers are initially set to accept cookies. If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all of the cookies on your computer by following your browser’s help file directions. Please refer to your browser instructions to learn more about how to adjust or modify your browser settings. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features on our Site. Please note that browser-management tools for cookies are outside of our control, and we cannot guarantee their effectiveness.
Security of Your Personal Data
We use commercial reasonably physical, technical and administrative security measures to reduce the risk of loss, misuse, unauthorized access, and disclosure. Please note, however, that no security measures are perfectly secure, and we are unable to guarantee the security of your Personal Data.
Third Party Websites and Applications
Our Site may contain links to websites or applications hosted by third parties. Any data collected through third party websites or applications shall be subject to the privacy practices of the third party, and you should review the privacy policies of these third parties prior to sharing any data.
Your Rights and Choices
Marketing Communications
We give you certain choices regarding our use and disclosure of your Personal Data for promotional purposes. You may opt-out from receiving electronic communications from us by contacting us as detailed in the “Contact Us” section below. If you no longer want to receive promotional-related emails from us, you may opt-out according to instructions in such communications. Please note that if you opt-out of receiving marketing-related messages, we may still send you important administrative messages.
Rights of California Consumers
We provide California consumers with specific rights regarding their Personal Data as required by California law. This section describes the rights that you have under California law and explains how to exercise those rights.
Right to Know About Personal Data Collected, Used, or Disclosed
You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Data. Once we receive your request and verify your identity, we will disclose to you: (a) the categories of Personal Data we collected about you; (b) the categories of sources for the Personal Data; (c) our business or commercial purpose for collecting or disclosing that Personal Data; (d) the categories of third parties with whom we shared that Personal Data; and (e) the specific pieces of Personal Data we collected about you in the preceding 12 months.
Right to Delete Personal Data Collected or Maintained
You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request and verify your identity, we will permanently delete (and direct our service providers to delete) your Personal Data from our records, unless a legal exception to deletion applies.
Right to Correction of Personal Data
You have the right to request that we correct inaccurate Personal Data that we maintain about you.
Exercising Your Rights
To exercise the rights described above, please submit a verifiable consumer request to us at techsupport@orchestraco.com.
Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.
Authorizing an Agent
You may designate an authorized agent to submit your consumer request on your behalf, so long as the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us.
Verifying Your Request
We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. To verify your identity, we ask that you provide us with the following information when you submit your request: (a) full name and (b) phone number or email. We will use the above information to verify your identity. Depending on your type of request or the information requested by you, we may require additional information to verify your identity and fulfill your request.
Rights of EU and UK Data Subjects
The EU’s General Data Protection Regulation and the UK Data Protection Act and UK General Data Protection Regulation provide EU and UK data subjects with additional rights described below. We generally act as a data controller of EU and UK data subject’s Personal Data submitted to us. We rely on that Personal Data for the legitimate commercial purposes of providing our Services. Where we need to collect Personal Data by law or under the terms of a contract we have with you, and you fail to provide that Personal Data when requested, we may not be able to provide you with our Services. We consider and balance any potential impact on you and your rights before we process your Personal Data. We do not use your Personal Data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law. In certain circumstances, we act as a data processor, and, in those circumstances, we process your Personal Data for the purposes set out in this Policy consistent with the data processing terms of those partners. If we are relying on your consent to process your Personal Data, you have the right to withdraw your consent at any time by contacting us at the information below. We will only use your Personal Data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you are located in the EU or UK and would like to: (a) access your Personal Data; (b) transfer your Personal Data; (c) request the erasure of your Personal Data; (d) object to the processing of your Personal Data; or (e) change your privacy preferences, please contact us at techsupport@orchestraco.com. Please note that there are certain exceptions and restrictions of these rights under the European data privacy laws that enable Personal Data to be retained, processed or withheld from access, and we will inform you of these exemptions and restrictions, if applicable. If you are located in the EU or UK and have any complaints regarding our privacy practices as a data controller, you have the right to make a complaint at any time to your local Supervisory Authority. However, we would appreciate the chance to address your concerns before you approach your Supervisory Authority, so please contact us first at the information below.
Cross-Border Data Transfers
We process Personal Data both inside and outside the United States. When appropriate, we execute EU and UK Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our customers that operate in the EU and the UK, and make transfers of Personal Data from those jurisdictions to the United States and other countries that lack adequacy determinations. Please contact us as detailed in the “Contact Us” section below for more information. In addition, we may transfer your Personal Data if one of the legal exceptions for such transfer can be invoked, such as with your consent or in execution of an agreement you have with us.
Personal Data Concerning Children
Our Sites is not intended for anyone under the age of 16. We do not knowingly collect Personal Data from individuals under the age of 16, unless the Personal Data is submitted with verifiable parental consent.
Updates to the Policy
We may update this Policy periodically as we offer new products and services, and as our business, technology, and laws change. You can determine when this Policy was last revised by referring to the “Last updated” reference below. Any changes will become effective upon posting of the revised Policy. If we make material changes to the policy, we will provide notice to you of the changes as required by applicable law.
Contact Us
Tech Support Team
Email: techsupport@orchestraco.com
Last updated: March 18, 2024.