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PRIVACY POLICY
Root Tribez LLC is committed to and has a long-standing policy of maintaining the privacy and security of your personal information. Personal information is information about an identifiable individual (as defined by applicable privacy or data protection laws).
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Root Tribez LLC’s Privacy Policy describes Root Tribez LLC’s practices with respect to the processing of your personal information which includes the collection, use, processing, transfer, storage or disclosure of your personal information, except where a Root Tribez LLC subsidiary or affiliate has published its own separate privacy policy. In addition, agreements or notices associated with a particular Root Tribez LLC product, service, software or website (“Root Tribez LLC Offering”) may provide additional information about Root Tribez LLC’s processing of your personal information (“Notice”). The application of the Root Tribez LLC Privacy Policy remains subject to applicable laws including legislation, regulations and the orders of courts or other lawful authorities, other lawful requests or legal processes. Where applicable, the Root Tribez LLC entity with whom you have entered an agreement is the data controller of your personal information.
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1. Accountability
Root Tribez LLC is responsible for personal information under its control, including the onward transfer of personal information to a third party for processing on Root Tribez LLC’s behalf.
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2. Purposes for Using Your Personal Information
When you use a Root Tribez LLC Offering, correspond with BlackBerry, enter a contest sponsored by Root Tribez LLC or otherwise interact with Root Tribez LLC, Root Tribez LLC may process your personal information for the following purposes:
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to understand and meet your needs and preferences, and to provide you with Root Tribez LLC Offerings, e.g.:
for purposes related to the billing, activation, provision, maintenance, support, trouble shooting, resolving of disputes, deactivation, repair, refurbishment, replacement, upgrade or update of Root Tribez LLC Offerings;
to ensure Root Tribez LLC Offerings are technically functioning as intended and to help identify and troubleshoot issues;
to understand your use of the network or Root Tribez LLC Offerings by interpreting network performance and use metrics;
to fulfill or enforce Notices applicable to a Root Tribez LLC Offering;
to manage or respond to your inquiries;
to develop new and enhance existing Root Tribez LLC Offerings including to communicate with you about them using various means, e.g. to make available or send to you:
upgrades or updates, or notices of upgrades or updates of Root Tribez LLC Offerings or third party content or related products, services and software;
notices of promotions and upcoming events;
to manage and develop our business and operations, e.g.:
to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect Root Tribez LLC property;
to allow for business continuity and disaster recovery operations;
to enforce Root Tribez LLC’s legal rights;
for statistical purposes;
to meet legal and regulatory requirements and to respond to emergency situations, e.g.:
to respond to court orders, warrants or other lawful requests or legal processes;
to provide emergency assistance in situations that may threaten the life or physical safety of you or others;
or for any other purposes for which you have consented, such as those that may be set out in Notices, and other purposes as permitted or required by any applicable law.
3. Consent
Before using Root Tribez LLC Offerings, you may be required to agree to an applicable Notice that may contain additional information regarding Root Tribez LLC’s processing of your personal information. Your agreement to the Notice or use of Root Tribez LLC Offerings indicates your consent for Root Tribez LLC to process your personal information for Root Tribez LLC’s identified purposes.
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If you provide Root Tribez LLC with personal information about another person, you are responsible for ensuring you have that individual’s consent to do so. All personal information provided to Root Tribez LLC is subject to this policy.
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a) When Obtaining Consent is Not Required
In certain circumstances, your personal information may be processed without your consent depending on the jurisdiction and any applicable laws. For example, Root Tribez LLC may not seek consent:
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in the case of an emergency where the life, health or security of an individual may be threatened;
when legal, medical, or security reasons make it impossible or impractical to seek consent;
when personal information is necessary to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security
issues or to protect Root Tribez LLC property;
when disclosure is to a lawyer representing Root Tribez LLC;
to collect a debt;
to comply with a subpoena, warrant or other court order, lawful request or legal process; or
as may be otherwise required or permitted by law.
b) Children
Root Tribez LLC does not knowingly process personal information from individuals under the age of 13 without the consent of their parent or legal guardian.
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c) Aggregated or Anonymous Information
Root Tribez LLC reserves the right to process, sell, trade or rent aggregated or anonymous information that is not associated with or linked to an identifiable individual.
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4. Types of Personal Information Processed
The types of personal information that Root Tribez LLC may process can vary. For example:
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a) Account and membership information: Personal information processed could include your name, postal address, email address, telephone number, airtime service provider information, communications with Root Tribez LLC and any recorded complaints. Root Tribez LLC may also process your account credentials, passwords, profile information and other personal information you provide to facilitate the Root Tribez LLC Offerings you use.
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b) Applications: In some cases, Root Tribez LLC may process personal information about applications used on your device including Third Party Offerings (i.e. applications, products, services, software, websites or content provided by a third party, including an airtime service provider or application developer, that may be used in conjunction with Root Tribez LLC Offerings, but are not offered, operated or supported by Root Tribez LLC). Also, if you choose to use Third Party Offerings with your Root Tribez LLC account, certain personal information may be collected and disclosed to the third party, or from the third party to Root Tribez LLC, in order to facilitate or improve the services and functionality provided.
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c) Cloud-based or back-up data: If you use a cloud-based or back-up and restore service provided by or on behalf of Root Tribez LLC, personal information including contacts, email addresses, calendar, memo, tasks, display pictures, status messages, media files and other on-device information may be sent to Root Tribez LLC in order to facilitate or improve the use, remote access and restoration of that data on your device through the service provided.
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d) Cookies or similar technologies: A cookie is a small text file or piece of data that is downloaded to and stored on your computer or device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes the cookie. As part of Root Tribez LLC’s Offerings, Root Tribez LLC may use different types of cookies or similar technologies (“Cookies”) from time to time. Certain Cookies are necessary to facilitate your use of Root Tribez LLC Offerings (such as when you use a shopping basket) or to protect both you and Root Tribez LLC when you sign-in to certain services (such as storing your credentials to make it easier whenever you want to use Root Tribez LLC Offerings or to confirm that you are logged in). Other Cookies are more performance-related such as for analytics or contextual purposes to help us understand how users engage with Root Tribez LLC Offerings so we can provide new and enhanced Root Tribez LLC Offerings (such as which pages or features are most popular). Some Cookies are more function-related and help personalize your experience and make Root Tribez LLC Offerings easier to use (such as your language or jurisdiction preferences), or to help Root Tribez LLC display personalized content to you.
Other Cookies or similar technologies may be used for targeted advertising purposes (e.g. certain Root Tribez LLC Offerings may be supported by advertising revenue and display advertisements and promotions which may be targeted against non-personally identifiable attributes or aggregate data collected by Root Tribez LLC, and Root Tribez LLC or our service providers may place such advertising on Root Tribez LLC Offerings). Anonymized or aggregated information about usage of Root Tribez LLC Offerings may be provided in a form that does not personally identify you to our service providers as part of analytics services and to help manage online advertising. Most browsers are initially set to accept Cookies, but you can usually change your browser settings to refuse Cookies or to indicate when a Cookie is being sent. You can typically remove or block browser Cookies using the settings in your browser, but that may impact your ability to use certain Root Tribez LLC Offerings as they may not work well or at all with Cookies disabled. Please visit the section below on "Withdrawing Your Consent" for more information on managing Root Tribez LLC’s use of Cookies.
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e) Financial information: If you purchase a product, service, software or customer support directly from Root Tribez LLC or our service providers, Root Tribez LLC may process credit card or other payment information and use it to facilitate billing and credit services and conduct credit checks, as applicable. Similarly, Root Tribez LLC may process payment or other financial information when you use Near Field Communications functionality.
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f) General usage data: In some cases, personal information that includes technical properties and general usage information of software and hardware utilized in conjunction with a Root Tribez LLC Offering might be processed when you use such products, services or software (e.g. type of web browser, referring or exit web pages, operating system version, hardware model of your device or personal computer platform, IP address), or when you use a Root Tribez LLC troubleshooting tool (e.g. basic usage statistics or information about your device including event logs, application configurations, battery life, radio or Wi-Fi signal levels, device reset and memory or system performance information).
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g) Location information: When you use Root Tribez LLC Offerings, enable data services, use the browser or location-based functionality on your device, location information associated to your device (e.g. Global Positioning System (GPS) or similar satellite triangulation information, carrier or tower ID, the BSSID (Broadcast Service Set Identifier) and MAC address (Media Access Control address) of Wi-Fi access points, and signal strength of visible Wi-Fi hotspots or wireless towers) may be communicated to Root Tribez LLC or our service providers. If Root Tribez LLC collects and subsequently stores such information, it will be in a form that does not personally identify you (e.g. BlackBerry does not maintain a system that would link specific individuals to a BSSID). Root Tribez LLC may process such information to provide you with or facilitate the provision of information and location-based services (e.g. mapping services, measuring traffic congestion, location-sensitive promotions or coupons). If you choose to use location-based services, you agree that such geographic location information may be processed to provide you with such services. You may manage through the settings on your device either the overall settings for your device’s GPS or location functionality or individual settings for each application. If you choose to use location-based services or other applications to disclose your location to other persons or entities, you assume responsibility for the risks involved in doing so, and it is your responsibility to use them appropriately and according to applicable law. If you use Third Party Offerings which provide location-based services, please review the third party’s terms and conditions and privacy policy regarding how your location and personal information will be processed, and how to opt-out of any location-based services and advertising provided by the third party.
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h) Quality assurance and customer service: Your customer service telephone calls with Root Tribez LLC and Root Tribez LLC’s service providers may be recorded or monitored for quality assurance and customer service purposes such as to assist in addressing your inquiries, troubleshooting, training and analytics to identify trends and make improvements to Root Tribez LLC Offerings.
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i) Third party information: If necessary to fulfill Root Tribez LLC’s identified purposes, Root Tribez LLC may combine the information you submit to Root Tribez LLC with information obtained from other sources or Third Party Offerings. For example, Root Tribez LLC may receive personal information about you from third parties involved in providing you with the products, services, software and websites you are utilizing, such as from your airtime service provider to facilitate the wireless services you are utilizing or in some cases from a Third Party Offering vendor regarding applications used on your device. BlackBerry treats all such personal information in accordance with this Privacy Policy and the terms and conditions between Root Tribez LLC and such third parties, if any. However, the third party’s own use of your personal information in such cases will be determined by your agreement(s) with the third party, unless that third party is a Root Tribez LLC service provider.
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Some of this information would not by itself identify you to Root Tribez LLC or be personally identifiable and is therefore considered non-personal information. If Root Tribez LLC combines any such non-personal information with other personal information available to Root Tribez LLC, the combined information will be treated as personal information in accordance with this Privacy Policy.
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j) Gmail user data use limitations: When you allow Root Tribez LLC Offerings to access your Gmail account, BlackBerry Offerings will only access and use Gmail user data, which includes messages, attachments, contacts, metadata, and settings, to provide you the ability to compose, send, read, and process email messages and manage your contacts. Root Tribez LLC Offerings will not transfer Gmail user data to Third Parties unless necessary to provide or improve the features of the Root Tribez LLC Offering, comply with applicable law, or as part of a merger, acquisition, or sale of assets. Root Tribez LLC Offerings will not use Gmail user data for serving ads, or interest-based advertising. Root Tribez LLC personnel will only access aggregated and anonymized data and will not access Gmail user data unless you have provided your affirmative consent for specific messages, or unless doing so is necessary for security purposes such as investigating abuse, to comply with applicable law.
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5. Processing Your Personal Information
a) Retention
Root Tribez LLC retains personal information as long as necessary for the fulfillment of Root Tribez LLC’s identified purposes or as otherwise necessary to comply with applicable laws. When personal information is no longer necessary or relevant for Root Tribez LLC’s identified purposes, or required by applicable laws, Root Tribez LLC will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. Consistent with good business practice, Root Tribez LLC continues to evolve our controls, schedules and practices for information and records retention and destruction which apply to your personal information.
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b) International operations and onward transfers
Root Tribez LLC has an international presence, with offices and facilities in multiple jurisdictions. Except where a Root Tribez LLC subsidiary or affiliate has its own separate privacy policy, all of Root Tribez LLC’s international operations and onward transfers are subject to this Privacy Policy.
You agree that, to be able to better serve you and facilitate the use or functioning of Root Tribez LLC Offerings, your personal information may be collected, used, processed, transferred or stored by or on behalf of Root Tribez LLC in multiple jurisdictions including Canada, the United States, the European Economic Area, and any other country where Root Tribez LLC or our service providers have offices or facilities, including countries which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of Root Tribez LLC.
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Given the international nature of our business, Root Tribez LLC may also be required to disclose or otherwise provide access to your communications data, including the contents of your communications, and other personal information under the laws of countries where Root Tribez LLC, our service providers, affiliates and data are located. By using Root Tribez LLC Offerings, you consent to our compliance with applicable laws including any legal process that Root Tribez LLC believes requires that we produce or provide access to your communications data and other personal information.
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c) Marketing communications from Root Tribez LLC
Root Tribez LLC may communicate information, surveys, marketing materials, advertisements or customized content which has been personalized to try to make it more relevant to you as part of your existing business relationship with Root Tribez LLC. For example, we may do so where you have not unsubscribed from receiving such communications and it is permitted by law, where you have explicitly agreed to receive such communications, where you use free services which rely upon advertising (including targeted advertising based on profile information), or through utilizing aggregated data or data that has been made anonymous. Root Tribez LLC may ask you from time to time if you would like to receive from Root Tribez LLC or authorized third parties selected by Root Tribez LLC additional announcements, news, offers or event invitations regarding Root Tribez LLC and Root Tribez LLC Offerings. You may also choose to provide Root Tribez LLC with personal information in response to various Root Tribez LLC promotions. If you agree to participate in contests, surveys, giveaways, reviews, or other promotions that Root Tribez LLC sponsors or co-sponsors, please ensure that you read the Notice that may be associated with these initiatives in order to obtain further details about how your personal information will be managed. An unsubscribe mechanism is included with every Root Tribez LLC marketing or commercial communication. Please visit the section below on “Withdrawing Your Consent” for more information on managing marketing or commercial communications from Root Tribez LLC.
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d) Service-related communications from Root Tribez LLC
Root Tribez LLC may also send you certain service-related communications. For example, Root Tribez LLC may send a welcome email or message when you first activate a Root Tribez LLC Offering to inform you about the service and its terms, to notify you of important changes, to tell you how to manage your credentials or account, to provide service infrastructure notifications or information about upgrades or updates, to provide warranty information, product recall information, safety or security information, or for surveys of current or former users. Because such service-related communications are important to your use of BlackBerry Offerings, you may not opt-out of receiving these communications.
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e) Information sharing
In accordance with this Privacy Policy, Root Tribez LLC may share your personal information within Root Tribez LLC and with our service providers. Root Tribez LLC may also share your personal information with our financial, insurance, legal, accounting or other advisors that provide professional services to Root Tribez LLC. Root Tribez LLC may also share your personal information in a manner consistent with this Privacy Policy with third parties involved in providing Root Tribez LLC Offerings to you including, but not limited to, airtime service providers, authorized resellers, distributors, merchants of record or payment processors, subcontractors or entities participating in Root Tribez LLC’s supply or repair chains.
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When you purchase or use a Third Party Offering (e.g. paid content subscription service, downloaded application), may share certain personal information with the third party for purposes of providing you with the product, service or software and your personal information will then be subject to the third party’s privacy policy. We encourage all our users to learn about the privacy practices of such third parties before agreeing to purchase or obtain their products, services or software.
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Root Tribez LLC uses contractual or other means to provide a comparable level of protection while the personal information is being processed by our service providers. It is Root Tribez LLC’s policy to enter into confidentiality obligations with any third party that obtains confidential information including personal information from Root Tribez LLC. For example, except where Root Tribez LLC is required or permitted by law to disclose personal information, our service providers to whom we provide your personal information typically agree to hold the personal information in confidence and only use the it for the purposes for which it was provided or to comply with applicable laws.
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In the event of the sale of all or a portion of Root Tribez LLC’s assets, Root Tribez LLC may provide personal information to the third party purchaser.
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Root Tribez LLC may utilize third parties (e.g. advertising networks) to target advertisements at non-personally identifiable attributes or aggregated data that is derived from profile data processed by Root Tribez LLC, and provide such third parties with general statistics relating to the advertisements delivered. Please visit the section below on “Withdrawing Your Consent” for more information on managing marketing or commercial communications from Root Tribez LLC.
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f) Third Party Offerings
Root Tribez LLC does not own or operate all the applications or services that you download and use on your device or through other Root Tribez LLC Offerings. When you download or utilize Third Party Offerings, personal information from your device or other Root Tribez LLC Offerings may be accessed by such third parties. For example, a Third Party Offering might access on-device data such as contacts, calendar entries, email, location-based information, or it may access or share files or data stored on the device (including with additional Third Party Offerings). You should review the privacy policies and any agreements with such third parties to understand how your personal information will be processed by those entities, as Root Tribez LLC is not responsible for your dealings with third parties or their applications, products, services or software. Root Tribez LLC does not directly control how such third parties process the personal information they collect in connection with the Third Party Offerings you use.
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In some cases, you may adjust the permissions granted to Third Party Offerings. You should periodically review these permissions including default permissions, as well as the Options or Settings menu on your device, in order to learn more about its security and available controls.
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6. Accuracy of Your Personal Information
Root Tribez LLC takes reasonable steps to ensure that personal information is sufficiently accurate, complete and up-to-date. Root Tribez LLC also depends on you to update or correct your personal information whenever necessary.
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7. Safeguarding Your Personal Information
Root Tribez LLC continues to evolve our physical, organizational and technological measures used to protect your personal information. For example, if a Root Tribez LLC website requests your name and password, it will have a variety of security measures in place that are designed to protect against the loss, misuse and unauthorized alteration of the personal information submitted to Root Tribez LLC. Through Root Tribez LLC’s Code of Business Standards and Principles, Root Tribez LLC employees are made aware of the importance of appropriately and securely handling personal information, to keep it in secure locations and systems, and to limit access to personal information to those with a need to know it for business reasons.
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In addition, certain Root Tribez LLC systems and processes are externally inspected on a regular basis.
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a) Your obligations to safeguard your personal information
You have an obligation to safeguard your personal information. You can reduce risk of unauthorized access to your personal information by using common sense security practices. For example, you are responsible for utilizing appropriate security measures to control access to your device and computer system, such as creating a strong password that cannot be easily guessed by others (e.g. by including punctuation marks, numbers, capital and lowercase letters, and choosing a password of an appropriate length and which does not include your name or account name), using different passwords for different services and using up-to-date antivirus software.
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As noted above, in some cases, you may adjust the permissions granted to Third Party Offerings. You should periodically review these permissions including default permissions, as well as the Options or Settings menu on your device, in order to learn more about its security and available controls.
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If you return, sell, discard, or transfer your device or other Root Tribez LLC product to another person or entity (such as providing your device to Root Tribez LLC or another entity for repair, refurbishment or replacement), you should ensure that the device and any associated accessories and peripherals are removed or securely wiped of any personal information or other sensitive data they might contain (e.g. SIM cards, microSD cards). You should also disassociate your device from all email accounts and other data services so that email and data are no longer directed to the device (e.g. push services, emails delivered through the Root Tribez LLC Internet Service, remote backup). Otherwise, your personal information may be available to a subsequent user of the device, and you may incur subscription and network data charges. You may learn more about how to take steps to protect yourself through the Options or Settings menu on your device, searching support articles online at www.fhtii.com, or by contacting your airtime service provider.
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8. Root Tribez LLC’s Ongoing Efforts to Be Transparent
Root Tribez LLC continues to make available information to help our users better understand Root Tribez LLC’s processing of personal information and how to exercise choices regarding the use of your personal information through various channels including this Privacy Policy, applicable Notices and additional information that may be made available from time to time on various Root Tribez LLC websites or on your device.
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9. Accessing Your Personal Information
Upon written request, Root Tribez LLC will inform you whether it holds personal information about you and provide you with access to your personal information within a reasonable timeframe and at minimal or no cost in accordance with applicable laws. If you identify an inaccuracy or incompleteness in your personal information, Root Tribez LLC will amend your information and notify any third parties as required by applicable laws.
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In certain situations, and depending on applicable laws, Root Tribez LLC may not be able to provide access to all of the personal information that it holds about you. For example, Root Tribez LLC may not provide access to personal information if doing so:
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would likely reveal personal information about a third party;
could reasonably be expected to threaten the life or security of another individual;
would reveal Root Tribez LLC or third party confidential information;
includes information that is protected by solicitor or attorney client privilege;
or includes information that was processed in relation to the investigation of a breach of an agreement or a contravention of a law.
In order to safeguard your personal information from unauthorized access, Root Tribez LLC may ask that you provide sufficient information to identify yourself prior to providing access to your personal information.
Depending on the circumstances and applicable laws, Root Tribez LLC may refuse to process certain access requests (e.g. access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).
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10. Questions or Concerns
Root Tribez LLC welcomes your questions or comments regarding this Privacy Policy and the way we process your personal information. If you have any questions, concerns or wish to contact Root Tribez LLC’s Data Protection Officer or request access to your personal information pursuant to applicable privacy or data protection laws, please contact BlackBerry either by email or in writing and we will use commercially reasonable efforts to respond:
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Facebook: Root Tribez LLC
a) Withdrawing Your Consent
At any time, you may withdraw your consent for Root Tribez LLC to process your personal information in accordance with this Privacy Policy, subject to legal or contractual restrictions and reasonable notice. For example, although you can use BlackBerry Offerings for some purposes without providing us with any personal information, Root Tribez LLC may need to process personal information for some services, including those that require payment or involve an ongoing relationship such as registration or subscription services. As such, Root Tribez LLC may continue to use your personal information as may be required to provide you with requested services, and to the extent that Root Tribez LLC is contractually obligated to do so or as necessary to enforce any contractual obligations you may have with Root Tribez LLC. If you refuse to provide Root Tribez LLC with the personal information it requires or later withdraw your consent to use and disclose this information, Root Tribez LLC may no longer be able to provide you with your Root Tribez LLC Offerings.
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You may withdraw your consent at any time by notifying the Privacy Office at Root Tribez LLC’s Facebook.
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Root Tribez LLC will occasionally update this Privacy Policy so that it remains relevant and current with changing technologies, applicable laws, our evolving business practices and the needs of our users. Root Tribez LLC encourages you to periodically review this Privacy Policy to stay informed of how Root Tribez LLC manages your personal information. If changes are made to this Privacy Policy, Root Tribez LLC will revise the “Last Updated” date that is indicated on the Privacy Policy.
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If material changes are made that impact you, we will notify users by placing a prominent notice at www.fhtii.com. Depending on the circumstances, we may also decide to send users a notice electronically. If you continue to use your Root Tribez LLC Offerings after notice of the change has been given, you will be deemed to have accepted such changes.
Last Updated June 20, 2019