Privacy Policy


Rachel Development (“Company”, “we”, “us” or “our”) respects the privacy of its users (“user” or “you”) that use our website located at, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Website”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that the Company may gather about, or collect from you, in connection with your use of the Website. It also is intended to explain the conditions under which the Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Website.

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using the Website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use, and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the Website.


Gathering, Use, and Disclosure of Non-Personally-Identifying Information


“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, the Company gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating, and immediately after leaving the Website. Although such information is not Personally-Identifying Information, it may be possible for the Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity, as well as other statistical usage data. The Company analyzes Non-Personally-Identifying Information gathered from users of the Website to help the Company better understand how the Website is being used. By identifying patterns and trends in usage, the Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, the Company may also release anonymized Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.


A “Web Cookie” is a string of information which assigns unique identifications to users that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. We use cookies on the Website to keep track of services users have used, to record registration information regarding login names and passwords, to record your user preferences, to keep users logged into the Website, and to facilitate purchase procedures. The Company also uses Web Cookies to track the pages that users visit during each Website session, both to help the Company improve users’ experiences and to help the Company understand how the Website is being used. As with other Non-Personally-Identifying Information gathered from users of the Website, the Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help the Company, its partners, and others better understand how the Website is being used. USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.


A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. The Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique the Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. Users may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying browser setting to notify users each time a Web Cookie is tendered, permitting users to accept or decline Web Cookies on an individual basis.


The Company may partner with selected third parties to allow tracking technology on the Website, which will enable them to collect data about how users interact with the Website and our services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity.


The Company may share aggregated, anonymized Personally Identifying Information and Non-Personally Identifying Information we collect under any of the above circumstances. The Company may also share aggregated, anonymized Personally Identifying Information and Non-Personally Identifying Information with third parties and our affiliate companies to develop and deliver targeted advertising on the Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated, anonymized Personally Identifying Information and Non-Personally Identifying Information with third parties, including advisors, advertisers, and investors, for the purpose of conducting a general business analysis. For example, the Company may tell our advertisers the number of visitors to the Website and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope users will find of interest and to target content and advertising.


The Company may use hyperlinks on the Website which will redirect users to a social network if clicked on the respective link. However, when users click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and the browser will directly connect to that provider’s servers. If users do not use these buttons, no data will be sent to the respective social network’s plugin provider. So, for example, when you click on the Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within the Company’s control.

The collection, Use, and Disclosure of Personally-Identifying Information


As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. The Company may collect a range of Personally-Identifying Information from and about users. Much of the Personally-Identifying Information collected by Company about users is information provided by users themselves when: (1) registering for the service, (2) logging in with social network credentials, (3) participating in polls, contests, surveys or other features of the service, or responding to offers or advertisements, (4) communicating with the Company, (5) creating a public profile, or (6) signing up to receive newsletters. That information may include each user’s name, address, email address and telephone number, and, if users transact business with the Company, financial information such as payment method (valid credit card number, type, expiration date or other financial information). The Company also may request information about users’ interests and activities, gender, age, date of birth, username, hometown, and other demographic or relevant information as determined by the Company from time to time. Users are under no obligation to provide the Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.



The Company may occasionally use names and email addresses of users to send notifications regarding new services offered by the Website. We may also send users service-related announcements from time to time through the general operation of the Website. Generally, users may opt out of such emails at the time of registration or through account settings, though the Company reserves the right to send users notices about their accounts, such as service announcements and administrative messages, even if the user opts out of all voluntary email notifications.


The Company will disclose Personally-Identifying Information under the following circumstances:

  • By Law or to Protect Rights. When the Company believes disclosure is appropriate, we may disclose Personally-Identifying Information in connection with: (i) efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of the Company, users, our employees or others; to comply with applicable law or cooperate with law enforcement; (ii) to enforce our Terms of Use or other agreements or policies; (iii) in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; (iv) to defend against legal claims; or (v) as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
  • Marketing Communications. Unless users opt-out from receiving Company marketing materials upon registration, the Company may email users about products and services that the Company believes may be of interest to them. If users wish to opt-out of receiving marketing materials from the Company, users may do so by following the unsubscribe link in the email communications, by going to the account settings (if applicable), or contacting the Company using the contact information below.
  • Third-Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Website’s functionality and supporting contests, sweepstakes, surveys and other features offered through the Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
  • Business Transfers; Bankruptcy. The Company reserves the right to transfer all Personally-Identifying Information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sales of all or a portion of the Company’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally-Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.

Users may, at any time, review or change their Personally-Identifying Information by going to account settings (if applicable) or by contacting the Company using the contact information below. Upon your request, the Company will deactivate or delete users’ accounts and contact information from the active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law. To make this request, either go to your account settings (if applicable) or contact us as provided below. We will retain in our files some Personally-Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use, and to comply with legal requirements as is permitted by law. Therefore, users should not expect that all Personally-Identifying Information will be completely removed from the Company’s databases in response to requests. Additionally, the Company will keep a history of changed information to investigate suspected fraud with an account.


The Company uses the Personally-Identifying Information in the file we maintain about you, and other information we obtain from your current and past activities on the Website, to (1) deliver the products and services that you have requested; (2) manage your account and provide you with customer support; (3) communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties; (4) develop and display content and advertising tailored to your interests on the Website and other sites; (5) resolve disputes and troubleshoot problems; (6) measure consumer interest in our services; (7) inform you of updates; (8) customize your experience; (9) detect and protect the Company against error, fraud, and other criminal activity; (10) enforce the Terms of Use; and (11) do as otherwise described to you at the time of collection. At times, the Company may look across multiple users to identify problems. In particular, the Company may examine Personally-Identifying Information to identify users using multiple user IDs or aliases. The Company may compare and review Personally-Identifying Information for accuracy and to detect errors and omissions. The Company may use financial information or payment method to process payment for any purchases made on the Website, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

Collection and Use of Information by Third Parties Generally

The Company contractually prohibits its contractors, affiliates, vendors, and suppliers from disclosing Personally-Identifying Information received from the Company, other than in accordance with this Privacy Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to Personally-Identifying Information that users provide directly to those third parties, or that those third parties collect for themselves. These third parties include advertisers, providers of games, utilities, widgets, and a variety of other third-party applications accessible through the Website. The Company neither owns nor controls the third-party websites and applications accessible through the Website. Thus, this Privacy Policy does not apply to information provided to, or gathered by, the third parties that operate them. Before visiting a third party, or using a third-party application, whether by means of a link on the Website, directly through the Website or otherwise, and before providing any Personally-Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in those users’ discretion, protect their privacy.


The Company takes the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures.

The Company is dedicated to protecting all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.

Privacy Policy Changes

The Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to the Privacy Policy will be reflected on this page, and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, the current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. The Company will always post new versions of the Privacy Policy on the Website. However, the Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.


The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. The Company does not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally-Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age, on or through the Website, then the Company will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Website, or has otherwise transferred Personally-Identifying Information to the Website, please contact the Company using our contact information below to have that account terminated and information permanently deleted.

California Privacy Rights

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits users who are California residents to request and obtain from us, once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.

Personal Data Protection

The Company is committed to protecting the personal data it collects or processes per the Information Security Policy. Additionally, The Company fulfills its obligations under the European Union’s General Data Protection Regulation (EU GDPR). Questions related to EU GDPR and/or data subject rights should be directed to the data privacy officer using the contact below.

Do-not-track Policy

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.