Room & Board, Inc. is committed to respecting your private information and protecting it from misuse. Our Privacy Policy outlines our current policy on personally identifiable information concerning consumers, and covers the operations of our stores, our catalog and telephone sales, and within our Web site. We encourage you to read it whenever you visit our stores, catalogs or Web site, since we may change this policy from time to time due to enhancements to our systems or changes in the law. A copy of the current policy is always posted at www.roomandboard.com/privacy/. You may also obtain a copy of the current policy by contacting the office of the Privacy Officer shown at the end of this policy.

Basic Privacy Principles

The following "Basic Privacy Principles" apply throughout our entire enterprise, whether we gather information through our stores, our catalog operations, or our Web site.

We consider certain information which we may learn or create while we engage in our business to be a consumer's "personally identifiable information." This includes any "identity information" which directly identifies a person by name, address, telephone number, e-mail address, government-issued number such as a social security number, or financial account identifier such as a credit card number. Personally identifiable information also includes information which is directly associated with identity information, such as information about the identified person's purchases to the extent the information is directly associated with that person's identity information.

We do not consider all information that we may gather or create in operating our business to be personally identifiable information. Basically, if information is not identity information or directly associated with identity information, we do not consider it to be personally identifiable information. For example, a database of our customers' purchases in aggregate which does not identify the individual customers would not be personally identifiable information.

Without your consent or as specified below, we will use your personally identifiable information which we learn through our interactions with you only for the purposes you would reasonably anticipate us doing. This includes use to contact you to answer your questions, to fulfill orders, to obtain billing or payment information, to follow-up on prior orders to ensure your satisfaction, and to contact you with additional information where you have permitted us to do so.

We do not share, sell or trade your personally identifiable information with third parties.

We may disclose some of your personally identifiable information to one or more of our own service providers that we may use to fulfill services for you, provided that we will reasonably assure that those service providers are obligated to maintain the confidentiality of your personally identifiable information and only use it for the purposes we hire them for. We may also disclose personally identifiable information to others if we are required to do so by law, to protect and defend the rights of Room & Board, Inc., or in the event of a corporate sale, merger, reorganization, dissolution or similar event.

The security of your personally identifiable information is important to us. Although we cannot guarantee against loss, misuse, alteration, unauthorized disclosure or destruction of data, we use commercially reasonable security measures to protect you from such occurrences. If necessary in accordance with the law, we will disclose to you any known or reasonably suspected breach in security involving your personally identifiable information.

This Privacy Policy is intended to comply with applicable United States laws and regulations, including the laws of particular states where our stores or customers are located. Our stores are located in the United States, all catalog orders are placed to our operators located in the United States, and our Web site is targeted only to residents of the United States. If you are not a resident of the United States, please note that our information gathering practices may not be compliant with your own country's laws and regulations, and you should not share your personally identifiable information with us unless you are willing and able to be subject to United States laws concerning such disclosures.

Store and Catalog Operations

In addition to the Basic Privacy Principles discussed above, the following policies apply specifically to our Stores and our Catalog operations.

Our stores and catalog operations are available to you to discuss our products and services with a Design Associate, and you may place your orders through one of our Design Associates in the stores, or place a catalog order via postal mail or via telephone. When we take your order, we will obtain additional personally identifiable information including your payment information. We will only use that personally identifiable information from your order for purposes concerning the fulfillment of your order. In doing so, your personally identifiable information from an order may be used or shared among our different offices, representatives or service providers such as the store, our catalog sales offices, our warehouses, our headquarters, the manufacturers of products you have purchased, the freight carriers used to deliver products to you, installers or designers we have engaged to assist with your order, or our credit card merchant banks or other bankers. We will share only that portion of your personally identifiable information with third parties that is reasonably required to fulfill your order, and those third parties will be contractually obligated to use the personally identifiable information only for order-fulfillment purposes.

We will comply with our credit card merchant banks' requirements for the use and storage of your credit card information, such as obligations concerning the security of your credit card numbers, as well as any laws that apply to that information's use and storage.

Web Site

In addition to the Basic Privacy Principles discussed above, the following policies apply specifically to our Web site (www.roomandboard.com).

Our Web site allows you to shop our catalog and place orders by use of an e-commerce system provided by a third party e-commerce provider. The portions of our Web site that allow you to place an order by giving your personal information use industry standard encryption methods such as secure-socket layer ('HTTPS') technology to protect your information while in transit between your computer and our third party e-commerce provider's system. Also, all of your sensitive personal information (for example your credit card data and your order information) is encrypted while it is being processed and stored by our third party e-commerce provider. Once your order has been received by the third party e-commerce provider, your order information is transmitted to our offices by secure and encrypted methods, and we then process and fulfill your order using our normal catalog ordering system subject to the privacy policies described above.

Our third party e-commerce provider is under contract with us to maintain the confidentiality and security of your sensitive personal information, and not to use it for any purpose other than assisting with the transactions in your own orders. The third party provider is obligated under that contract to destroy your sensitive personal information once your transaction has been successfully transmitted to our offices. As a way to enhance our ability to protect your private information, we do not provide you with the ability to store your credit card (or similar) data on our Web site for future transactions, and we ask that you re-enter that information each time you place an order with us.

Our Web site gives you the option to create a personal account. To create an account, you will be asked to provide contact information and select a user name and password. This personally identifiable information may be used to provide you with personal services from us. You may also use the account to use our online personalized features. However, other than when submitting an order to purchase from our Web site, submitting contact information and creating an account are strictly voluntary and are not required to use our Web site.

Our Web site is not targeted to persons under the age of 13, and we will not knowingly collect personally identifiable information from persons under age 13 without prior parental consent. Barring knowledge to the contrary, we will presume that all personally identifiable information collected by our Web site is from persons age 13 and over.

Anonymous, non-personally identifiable information such as your IP address, domain server, type of computer, type of web browser, and addresses of referring site, also known as traffic data, may be collected and used to diagnose problems with our server and administer our site. We may also use cookies and action tags to collect information. Cookies and action tags allow us to compile statistics and other information about how you use our site. We may use this data to analyze trends and improve the usability of our site as well as to administer the site and gather broad demographic statistics. We may also share such non-personally identifiable information with third parties on an aggregate basis.

Our site may contain links to other Internet web sites that we think you may find of interest. We are not responsible for the content of these sites, nor do we control, sponsor, endorse or approve them. Your use of those links is at your own risk.

Opting out

If you request to receive information from us, we will naturally presume that you have given us permission to communicate with you about that information, either by postal mail, e-mail or telephone. Further, if you are engaged in transactions with one of our associates, and choose to use e-mail or telephone for communications about that transaction, we will presume again that you have given us permission to communicate with you about that transaction.

Apart from the above, you may opt-out of receiving future commercial communications from us. You may first do so at the point where we request information about you.

If you would prefer not to receive our e-mail updates, please use the functionality located at the bottom of each e-mail or visit the following url: www.roomandboard.com/unsubscribe/

We love to send you our annual catalog but only if you want it. Because of that, we've joined Catalog Choice, an organization that lets consumers indicate which catalogs they no longer wish to receive. If you would prefer to not receive our catalogs in the postal mail, or if you are receiving extra copies that you do not need, please visit catalogchoice.org.

You can also call our Customer Service telephone line at 800.301.9720 to be removed from either our e-mail or postal mail lists.

Correcting or updating your information

Click the following link to correct, change or update your personally identifiable information for the Web site account: www.roomandboard.com/account/

Privacy Officer

Please direct any questions or comments regarding our Privacy Policy to the office of our Privacy Officer:

Privacy Officer
Room & Board, Inc.
4600 Olson Memorial Highway
Minneapolis, Minnesota 55422
phone: 763.588.7525
e-mail: privacyofficer@roomandboard.com


Last updated: January 19, 2009