Privacy Policy

 

Last Updated: September 14, 2026

This Privacy Policy (“Privacy Po” or “Notice”) describes what personal information Rafar Group LLC and its operating groups, subsidiaries, affiliates, principals, owners, partners, and agents (“we,” “us,” or “our”) may collect from you through your use of our website, https://www.rafar.com, the personal information we may maintain, how we might use it, to whom we may disclose it, and the rights you may have with respect to your personal information. This Notice also describes other important topics relating to your privacy.

This Notice does not address our processing of the personal information of our job applicants, employees, and independent contractors for human resources, employment, benefits administration, health and safety, and other similar business-related and legal compliance purposes. This Notice also does not apply to information that has been de-identified, aggregated, or is otherwise exempted from applicable data protection legislation.

Individuals with disabilities may access this Notice in an alternative format by contacting (212) 743-6900 or legal@rafar.com. Certain terms used in this Privacy Notice have the meanings given to them in the applicable data privacy law.

Your Consent and Policy Changes

Please read this entire Privacy Notice carefully. By using the site, you expressly consent, without qualification, to the collection, use, and disclosure of information, including personal information, as described in this Privacy Notice. If you do not agree to the terms of this Privacy Notice, you are not authorized to use the site.

We may update this Notice to reflect changes in our privacy practices at any time and without prior notice to you. When we do so, we will update the Effective Date of the Notice, above. We encourage you to periodically review this Notice for the latest information on our privacy practices.

Personal Information We Collect

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. Depending on your interactions with us, including in the preceding 12 months, we may collect, process, and store certain categories of personal information about you, including, but not limited to:

  • Personal Identifiers, such as name, address, telephone number, or e-mail address, unique personal identifier (e.g., device identifier, unique pseudonym, or user alias/ID), online identifiers, login information, IP addresses, and other similar identifiers.

  • Internet or other electronic network activity information, such as information about your device(s) when accessing our website and your usage details of our website, you provide when filling in forms on our website, the type of browser you use, the files you request, and the domain name and country from which you request information, or information you provide when requesting further information, products, or services from us.

  • Professional and employment-related information, such as information relating to your position, (e.g., job title, job description, or department), employment status, employment history, or business email address.

  • Commercial information, such as records of products or services considered, or other purchasing or consuming histories or tendencies.

  • Geolocation data, such as time and physical location related to use of an internet website, application, device, or physical access to an office location.

  • Inferences and profiles based on other personal information, such as information about your behavior, preferences, characteristics, or predispositions.

  • Other information you choose to provide.

We do not process “sensitive personal information,” as defined by applicable data privacy law (including through analogous terms), without first obtaining your consent.

Sources of Personal Information

We collect and receive, and during the 12-month period prior to the effective date of this Privacy Notice, may have collected and received personal information from the following sources:

  • Directly from you when you provide it to us;

  • From third parties, such as our service providers, business partners, and customers; and

  • Automatically and indirectly from you, such as through logging and analytics tools, cookies, pixel tags, and other similar technologies on our website.

When you visit our website, third parties with whom we work may use cookies and other technologies to collect your personal information as well as other information about your online activities over time and across third-party websites or online services. The information generated by the cookies may include your IP address, your browser type, the date and time of your visit, the pages you visit and the amount of time spent on each, your device’s operating system, your mobile device identifier, your geographical area, referring URLs, and other information on your interaction with our site. For more information about how Google collects, uses, and discloses information, refer to the following page: https://policies.google.com/technologies/partner-sites.  You may be able to modify your cookie settings or turn off all or certain types of cookies by adjusting your browser settings. Please note, however, that if you delete or turn off cookies, you may not have access to some of the features that make your experience on our site smoother, you may not be able to store your preferences, and some portions of our website may not function properly.

Purposes for Using, Disclosing, and Otherwise Processing Personal Information

We may use, disclose, or otherwise process (and may have used, disclosed, or otherwise processed in the 12-month period prior to the effective date of this Notice) personal information for the following purposes:

  • Providing our website and supporting the features and contents available to you.

  • Personalizing your digital experience with us, including enhancing features and serving targeted advertising.

  • To respond to your inquiries and supply you with requested information about our products and services.

  • Understanding how you and others use our website and to determine what features and services may interest you or our others.

  • Operating and improving our organization, our services, and our market understanding.

  • Communicating with you and others, including but not limited to providing promotional content and transactional messages.

  • Troubleshooting, de-bugging, and otherwise addressing issues that may arise with the functionality of the websites.

  • Helping to ensure security and integrity, to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.

  • Protecting the legal rights, property, safety, and security of records or information, our organization and others, including detecting and preventing security incidents, fraud, misuse, harassment, and other malicious, deceptive, unauthorized, or illegal activity.

  • Complying with industry standards, applicable law, judicial process, any properly authorized civil, criminal, or government or regulatory investigation or request, or any subpoena or summons issued by a competent authority.

  • Enforcing our policies, terms of use, or rights arising from contracts.

  • For certain short-term transient uses.

In addition, we may also use, disclose, or otherwise process your personal information for such purposes as you may authorize at the time you submit the information or as otherwise compatible with the above purposes or your reasonable expectations.

De-identified personal information will not be subject to this Notice and will be used to the extent permissible and in accordance with applicable law. 

“Sales” of Personal Information, Targeted Advertising, and Profiling

We do not:

  • Process your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; or

  • Process personal information for purposes of targeted advertising, sell personal information, or profile in furtherance of decisions that produce legal or similarly significant effects concerning a consumer without the consumer’s consent, where we have actual knowledge that the consumer is under 18 years old.

We generally disclose, and in the preceding 12 months we may have disclosed, the categories of personal information listed above in “Personal Information We Collect” to the below categories of entities, including for business or commercial purposes as described in “Purposes for Using, Disclosing, and Otherwise Processing Personal Information”above:

  • To our subsidiaries and affiliates;

  • To our service providers we use to support our business, such as IT operating system and platform vendors, security vendors, and monitoring and data analytics providers; and

  • To other third parties, such as regulatory authorities or other third parties in response to legal process or other legal reporting requirements; to potential buyers (and their agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our stock or assets (including in the event of a reorganization, dissolution or liquidation); and to other similar third parties where disclosure is required for an ordinary business purpose in connection with our provision of services.

Our business model does not include selling your personal information to third parties in exchange for money. However, we do process online activity, such as cookies and the advertising identifier associated with your computer or mobile device, with our advertising partners for targeted advertising. Under certain state privacy laws, this may be considered a “sale” or processing for “targeted advertising.” We generally “sell” or process for targeted advertising, and in the preceding 12 months we may have “sold” or processed for targeted advertising, the following categories of personal information:

  • Identifiers

  • Internet or other electronic network activity information

  • Commercial information

  • Inferences

These categories of information have been and may be disclosed to our marketing and advertising partners, including platforms that enable or participate in targeted advertising, and social media platforms. Residents of certain jurisdictions may opt out of the processing of their personal information for the purposes of targeted advertising as described in Privacy Rights and Choices, below.

Retention of Personal Information

We retain personal information for as long as necessary to carry out the processing activities described in this Privacy Notice, including but not limited to providing and administering the website, providing you with our products or services, answering your queries, complying with applicable laws, regulations, rules, and requests of relevant law enforcement and/or other governmental agencies, and protecting our, our employees’, and our business partners’ and customers’ rights, property, or safety and the rights, property and safety of others. We may retain personal information for a longer period of time if a longer retention period is required or permitted by applicable law. In specific circumstances, we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

Confidentiality and Protection of Your Personal Information

We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we take measures to limit access to personal information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access. Although we use appropriate security measures once we have received your personal information, the transmission of information over the internet is never completely secure, so we cannot guarantee that your personal information will remain secure in all circumstances.

Third-Party Links

We may provide links to other websites and services for your convenience. If you choose to visit these other websites and services, your interactions will be governed by their privacy policies, if any, which you should review to learn more about their privacy practices. If you decide to access any of the third-party websites linked to our websites, you do so entirely at your own risk and subject to the terms and conditions of use for such third-party websites.

Privacy Rights and Choices

Residents of certain jurisdictions, including New Jersey, have specific legal rights regarding their personal information. This section describes the legal rights that may be available to you, depending on your jurisdiction of residence, and explains how to exercise them.

  • Confirm and Access: You may have the legal right to request, subject to certain limitations, that we confirm whether we process your personal information and to access such personal information.

  • Correction: You may have the legal right to request that we correct inaccuracies in the personal information we maintain about you, taking into account the nature of the information and the purposes of the processing.

  • Deletion: You may have the legal right to request that we delete certain personal information we have collected about you, subject to certain exceptions.

  • Portability: You may have the legal right to obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format that allows them to transmit the data to another entity without hindrance.

We will not discriminate against you in any way for exercising your privacy rights under applicable law.

Residents of jurisdictions that provide for the above rights may exercise their privacy rights by submitting a request to us at legal@rafar.com, or calling us at (212) 743-6900. We will verify the identity of data subjects before fulfilling data subject rights requests. Authorized agents may submit requests on behalf of data subjects if they provide proof of authorization, and we may also require the individual to verify their identity directly. We will respond to requests as required by applicable law. We may deny a request if we cannot verify identity or if the law otherwise permits.

If we deny the request, we will explain the basis for the denial and provide instructions on how the data subject may appeal our decision. If applicable state law grants the data subject the right to appeal our denial of their request to exercise their privacy rights, they may appeal our denial by contacting us at (212) 743-6900 or legal@rafar.com.

Opt-Out of Targeted Advertising or Profiling. You may have the legal right to opt out of the “sale” or processing of your personal information for purposes of targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects. To the extent we share your personal information for targeted or behavioral advertising purposes, you may choose to opt out of those disclosures on a going forward basis at any time. To exercise this right visit the cookie settings link in the footer of our website.

You may also be able to restrict the collection of personal information through your device’s operating system or by disabling cookies, but doing so may prevent you from using the functionality of the websites. If your browser supports it, you can turn on the Global Privacy Control (GPC) to opt out of the sale of your personal information or processing for targeted advertising. We honor the GPC and other universal opt out signals where we are required to do so by applicable law. These are signals you can send from your browser to a website to convey your choice to exercise certain opt-out rights.

Some internet browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our website does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

Even if you opt out of the sharing or processing of your personal information for targeted or cross-context behavioral advertising, you may still see our ads online at other sites and apps, and we may still base aspects of ads on your interactions with us and the websites.

Children’s Privacy

Our websites are not intended for or designed to attract children under the age of 18, and we will not knowingly solicit or collect personal information from children we actually know are under 18.

Contact Us

If you have any questions or comments about this Notice or our privacy practices, please contact us at (212) 743-6900 or legal@rafar.com.