Data Privacy Policy of Russell Westbrook Enterprises Inc.

Last Updated: July 10, 2020

Thank you for your interest in Russell Westbrook Enterprises, Inc. (“RWE” “we,” “us,” or “our”) and in our services. By utilizing any of our services, you agree and acknowledge that you are bound by this Data Privacy Policy. This Data Privacy Policy offers you information about how we deal with your personal and non-personal data, as (i) a visitor to our websites, (ii) a person who contacts us, or (iii) as a visitor to our clients’ websites and platforms (collectively, in connection with our “services”). The collection, processing and use of your data takes place in compliance with all applicable data protection regulations.

1. Personal Data

Personal data (or personal information) comprises all information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person or household, such as a real name, postal address, e-mail address, telephone number, payment information, and account ID. When other information is directly associated with personal data, that information may also be considered personal data. Information that is aggregated, de-identified, or anonymized is not considered personal data. Publicly available information that is made available from federal, state, or local government records, also may not be personal information.

For the purposes of compliance with the California Consumer Privacy Act of 2018 (“CCPA”), RWE is a covered business with respect to information that is provided by you, directly or automatically, when you visit Our Website. RWE is not a covered business with respect to activities RWE undertakes on behalf of its Clients, in which it acts as a service provider, or a third party. As such, this Data Privacy Policy does not cover the activities RWE undertakes on behalf of its clients. You may visit our Clients’ websites, or contact our Clients directly, should you wish to learn more about their personal information practices, or to assert any rights under the CCPA.

2. Collection of Personal data

The scope of how we collect and process personal data is determined by the way you get in touch with us or our technologies and services.

a. When you visit our website

This information may be provided by you directly or may be collected automatically from your device. We do not record any personal data (not your name, address, telephone number or email address) other than what is voluntarily provided by you when attempting to contact us via a form on Our Website.

i. Cookies

Our Website uses cookies. Cookies are small text files that are sent from our servers to your browser to be stored on your device. Cookies help improve and optimize the usability of websites and other online services, including Our Website. The cookie stores information, which is linked to respective devices used, and may include your IP address, or other device identifiers. Our use of cookies is compliant with any applicable cookie and data privacy legislation.

Most browsers accept cookies automatically. Visiting Our Website is possible without cookies. You may delete cookies stored in your browser at any time. You may also opt out of our use of cookies relating to Our Website on a specific device by using the following link If you delete your cookies, use a different browser, or use a different device, you will need to renew your opt-out choice.

You can find out more information about how to change your browser cookie settings at

Cookies used on Our Website are listed below.

Cookie name Purpose
Analytic cookies by Google Analytics, please find more information:
Wp32058 Third party cookie placed by Act-on for marketing and aggregation purposes. For more information about Act-On’s cookies, please visit

ii. Third Party Cookies

Cookies that are placed on your browsing device by a third party can be managed through your browser or by checking the third party’s website for more information about cookie management and how to “opt-out” of receiving cookies from them. If you would like more information about cookies and targeted advertisements or to opt out of having this information used by companies that are part of the Network Advertising Initiative, please visit

b. When you contact us

Regardless of how you contact us, we may collect personal data, such as your contact and identification information, including name, title, email address, postal address, and phone number. We may also collect any other personal data you provide to us in your communications with us.

c. Information collected and offered by third parties

In providing our technologies and services, including advertising services, to our clients, we may use information about your device, its unique ID, operating system and browser as well as your IP address. We do not collect this information directly from you but access this information through our relationships with third parties, including DoubleClick, who may collect it from you when you interact with third party websites. This information may include the referring URL, your geography (city, state, and zip code), and other electronic identifiers unique to you.

3. Processing and use of personal data

Visitors to our websites and those who contact us

We may use information collected from you in accordance with this Data Privacy Policy to: Provide, administer, and utilize Our Website; Provide the services you or others request; Communicate with you; Provide user or technical support; Perform analyses on the data we have collected, such as trends, and other research for statistical purposes; Measure and improve our products, business, products, services, and performance, including our programs and website layout and content; Prevent potentially fraudulent, prohibited, or illegal activities; and Comply with legal requirements, or assert or defend a legal claim.

Information collected and provided by third parties

We may use and access information collected about you or your devices by third parties for our own business purposes, which may include: Offering you products and services we believe you may be interested in; Measuring and improving our marketing products, services, and performance, including for our clients; and Performing analyses on the data we have collected, such as trends, and other research for statistical purposes.

We also use your personal data collected and provided by third parties in order to provide services to our clients. This Data Privacy Policy does not cover the activities RWE undertakes on behalf of its clients. You may visit our clients’ websites, or contact our clients directly, should you wish to learn more about their personal data practices.

4. Disclosure of Your Personal Data

RWE does not sell your personal data and will not sell your personal data. RWE may share some or all of your personal data:

If RWE believes in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on RWE ; (iii) to protect or defend the rights or property of RWE or users of Our Website; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law or this Data Privacy Policy.

In connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. If another company acquires our company, business, or assets, that company will possess the personal data collected by us and will assume the rights and obligations regarding your personal data as described in this Data Privacy Policy. In the unlikely event of an insolvency, bankruptcy, or receivership, personal data may also be transferred as a business asset.

5. Data Security

RWE takes all reasonable technical, physical, and organizational security measures required to protect your personal data from loss, unauthorized disclosure or other forms of misuse. Data is stored in a safe environment that is not open to public access. Our staff has been trained in privacy matters and in dealing with data and information, which they gain access to in a responsible manner.

6. Your Choices and Rights Relating to Your Personal Data

California Residents

If you are a California resident, the CCPA may afford you the right, following a verifiable request, to:

(1) access—twice in a 12-month period, free of charge—the categories and specific pieces of personal information RWE has collected about you, the categories of sources from which the personal information is collected, the business purpose for collecting the personal information, and the categories of third parties with whom RWE shares personal information, for the 12-month period prior to the request; and

(2) delete personal information under certain circumstances.

RWE does not discriminate against you on the basis of your exercising any rights afforded by the CCPA, which is further in accordance with California residents’ rights under that title.

You can make the above-mentioned requests by emailing, calling us at toll free 1-877-532-3436, or writing to us at 10960 Wilshire Blvd, 5th Floor, Los Angeles, CA 90024. Please specify in your request the details of what personal information you would like to access, correct, or delete. Please note that not all data described in this Data Privacy Policy will be subject to CCPA.

Following any request, we will verify your identity using data points you have previously provided to us. Please have this information available so that we can verify your request. You may also authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written permission to request on your behalf, and your authorized agent is able to verify their identity with us.

Further, in accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, STE 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to For more information about protecting your privacy, you may wish to visit:

7. Amendments to this Data Privacy Policy

We may modify this Data Privacy Policy from time to time, in particular if new laws and regulations are adopted or we regard amendments reasonable. The date of amendments will be posted below the heading of this Data Privacy Policy.

8. Links

Our Website may provide links to other websites. This Data Privacy Policy does not apply to third-party websites, even if they are linked to RWE’s websites. Other websites you visit may have their own privacy policies or no policy at all. Other websites might use personal information differently than our policy permits. RWE does not endorse these websites, is not responsible for the content of any third-party websites nor has any control over information you may choose to provide to those websites.

9. Contact

If you have any questions regarding this Data Privacy Policy, need to access this Data Privacy Policy in an alternative format due to a disability, or would otherwise like to contact us regarding this Data Privacy Policy, please email, call us at 1-855-773-8446, or write to us at the following address: 10960 Wilshire Blvd, 5th Floor, Los Angeles, CA 90024.