Privacy Policy
Effective Date: August 11, 2026 · Version 3.2
This Privacy Policy applies to coody.us (operated under the Coody brand), owned and operated by RBM Trading LLC (“RBM Trading,” “we,” “us,” or “our”).
1. Scope
This Policy describes how we collect, use, and share personal information when you:
- visit or make a purchase on coody.us (the “Site”);
- interact with our advertising links or marketing communications; or
- interact with redirect domains, tracking domains, and related storefronts that we operate or that operate on our behalf to deliver you to the Site.
Because a click on one of our ads may first pass through a redirect or tracking domain that we control before reaching the Site, this Policy covers that entire journey, not just the moment you land on coody.us.
This Policy does not apply to third-party websites, apps, or services that we do not own or control, even if linked from our Site.
2. Who We Are
RBM Trading LLC is the entity responsible for the collection, use, and disclosure of personal information described in this Policy. RBM Trading LLC is a Delaware limited liability company. Mailing address for correspondence: 25 Peterborough Street, Apt 22, Boston, MA 02215, United States (correspondence only — we do not operate a store or office at this location). Contact details are in Section 16 below.
3. Information We Collect
3.1 Information You Provide to Us
When you place or attempt to place an order, sign up for marketing communications, contact customer support, use website chat, or respond to a survey, we collect information such as:
- name, billing address, shipping address, email address, and phone number;
- order details (items purchased, order value, order history);
- payment and transaction information (see Section 3.4 below on payment cards);
- any information you choose to include in messages to us, including through our website chat, and any answers you choose to give in a post-purchase survey.
3.2 Information Collected Automatically
When you visit the Site, we and our service providers automatically collect certain information about your device and browsing activity, including:
- device and browser information (browser type, operating system, device identifiers);
- IP address and approximate location (such as city/region derived from IP);
- the web pages or products you view, and how you interact with the Site;
- referring and exit pages, and the site or search terms that referred you to us;
- date and time stamps and other log data.
We collect this information using cookies, log files, and similar technologies such as web beacons, tags, and pixels.
3.3 Advertising and Marketing Attribution Information
To understand which advertising sources lead to visits, carts, and purchases, we collect and process advertising click identifiers, first-party analytics identifiers, and transaction data to measure how advertising contributes to visits, carts, checkouts, and purchases. This includes identifiers passed in the URL when you arrive from an ad (such as a Facebook/Meta click identifier, a Google click identifier, our own click identifier, and identifiers set by affiliate or partner link tools when you arrive through such a link), and a first-party identifier assigned to your browser by us.
Full technical detail on the specific cookies and identifiers we use, what each one does, and how long each is retained is available in our Cookie Policy.
3.4 Payment Information
Payments on our Site are processed by Shopify Payments and other authorized third-party payment processors. We generally do not receive or store full payment card numbers. Any payment-related information you provide is transmitted directly to our payment processors in accordance with their own security standards and privacy practices.
3.5 Website Chat
Our Site may offer a website chat feature operated by a third-party chat service provider. If you use website chat, your messages and related metadata are processed by that provider on our behalf to respond to your inquiry. Please do not enter payment card numbers or other sensitive financial information into chat.
3.6 Post-Purchase Surveys
After a purchase, we may ask you optional questions — for example, how you heard about us or how you decided to buy — through a third-party survey provider. Answering is voluntary. Your responses are processed on our behalf to help us understand our marketing and improve our products and service.
3.7 Information from Other Sources
We may also receive limited information from our service providers (for example, delivery confirmations from shipping carriers or fraud-risk signals from fraud-prevention providers).
4. How We Use Your Information
We use the information described above to:
- fulfill and process orders, including payment processing, shipping, invoicing, and order confirmations;
- communicate with you about your order, account, or inquiries;
- screen orders and site activity for potential fraud or risk;
- operate, maintain, and improve our Site;
- measure and improve the performance of our marketing and advertising, including which channels and campaigns drive visits and purchases;
- provide you with information or advertising about our products, where consistent with your preferences and applicable law;
- comply with legal obligations and enforce our rights and agreements.
5. Marketing Attribution & First-Party Analytics
We use first-party marketing attribution technology to understand which advertising channels bring visitors who go on to purchase. In short: when you click one of our ads, an advertising click identifier and a first-party visitor identifier may be recorded and stored as part of your cart and order information. Our own tracking infrastructure — including redirect and tracking domains we operate — uses these identifiers to connect a purchase back to the ad or channel that generated it.
Where we match an order to an earlier visit using your email address, the email is processed in a pseudonymized form using cryptographic hashing (technical details are described in our Cookie Policy). We use this hashed value within our own systems to link an order to a prior visit. In addition, where server-side ad measurement (such as the Meta Conversions API) is active, a hashed identifier such as your hashed email may be transmitted to the relevant advertising platform (for example, Meta) in hashed form as a matching key, as described in Section 6 (Sharing Your Information).
We do not disclose this attribution data to data brokers and do not use it to build advertising profiles for sale to third parties. Our own attribution database is maintained on infrastructure we operate. Separately, where server-side ad measurement is active, we transmit hashed identifiers and conversion events to advertising platforms as described in Section 6.
For full details on specific cookies, identifiers, providers, categories, and retention periods, see our Cookie Policy.
6. Sharing Your Information
We share personal information with the following categories of recipients, each for the purposes described:
- Ecommerce platform provider. We use Shopify to operate our online store. Shopify processes personal information on our behalf. See Shopify’s privacy policy: https://www.shopify.com/legal/privacy.
- Payment processors. Shopify Payments and other payment processors receive the information necessary to process your transaction.
- Shipping and fulfillment providers. Carriers and fulfillment partners receive the information necessary to deliver your order.
- Advertising platforms. We work with advertising platforms, including Meta (Facebook/Instagram) and Google, to run and measure advertising campaigns. This may involve sharing limited identifiers or event data with these platforms so they can measure and optimize ad delivery. Depending on how they are used, these disclosures may be classified as a “sale” and/or “sharing” for cross-context behavioral advertising under U.S. state privacy laws. We treat them as both and provide a single opt-out that covers both. See Section 9 (U.S. State Privacy Rights) and our Your Privacy Choices page for how to opt out.
- Analytics and tracking service providers. Providers that support our first-party analytics, marketing attribution, and site-performance measurement.
- Survey providers. Providers that deliver our optional post-purchase surveys and process your responses on our behalf.
- Website chat provider. A third-party website chat service provider processes messages and related information you submit through website chat, on our behalf.
- Fraud-prevention providers. Providers that help us screen orders and site activity for potential fraud or risk.
- Email and marketing communications providers. Providers that send order confirmations and, where permitted, marketing emails on our behalf.
- Hosting and infrastructure providers. Providers that host our Site, redirect and tracking domains, and related infrastructure.
- Affiliate and partner link tools. Where you reach the Site through an affiliate or partner link, the link-management provider processes the click identifier used for attribution.
- Professional advisers. Accountants, auditors, lawyers, and other professional advisers, as needed for their services to us.
- Legal, safety, and compliance. Where required to comply with applicable law, respond to legal process (such as a subpoena or court order), enforce our terms, or protect the rights, property, or safety of RBM Trading, our customers, or others.
- Business transfers. In connection with a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction, subject to standard confidentiality protections.
Apart from the advertising-platform disclosures described above, we do not sell or share personal information. We use service providers that may process information on our behalf, under contractual confidentiality and data-protection obligations.
7. Data Retention
We retain categories of information as follows:
| Category | Retention Period |
|---|---|
| Raw click / attribution logs (tracking server) | Up to 256 days, then deleted |
First-party click-attribution cookie (rbm_ksubid) |
Up to 90 days |
First-party visitor identifier cookie (rbm_vid) |
Up to 365 days |
First-party advertising click-id cookies (rbm_fbclid,
rbm_gclid) |
Up to 90 days |
| Order-level attribution linkage (order-to-visit matching) | Up to 36 months after the last related activity, after which it is deleted or anonymized |
| Order and transaction records | For the period required by applicable tax, accounting, and recordkeeping laws |
| Marketing communication preferences / opt-outs | For as long as needed to honor your preference or choice |
Order records are retained separately from attribution data for tax and accounting purposes. Where information is no longer needed for the purposes described in this Policy, we delete or anonymize it, subject to legal, tax, accounting, fraud-prevention, and dispute-resolution requirements. For full cookie-level detail, see our Cookie Policy.
8. Do Not Track / Global Privacy Control
We recognize Global Privacy Control (GPC) as a valid opt-out preference signal. If you visit the Site with GPC enabled in your browser or browser extension, we treat it as a request to opt out of the “sale” and “sharing” of personal information for that browser and apply it automatically in the states where this is required — you do not need to take any further action. To have the opt-out applied to your account or email address across devices, use the opt-out page or contact us on our Your Privacy Choices page.
We do not currently alter our data practices in response to browser “Do Not Track” signals, as no uniform standard for such signals exists.
9. U.S. State Privacy Rights
Depending on where you live, you may have rights under state privacy laws such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), and similar laws in other states.
9.1 Categories of Personal Information
In the preceding 12 months, we have collected the following categories of personal information, as defined under CCPA:
- Identifiers (name, address, email, phone number, IP address, online identifiers, device identifiers)
- Commercial information (order history, products purchased)
- Internet or other electronic network activity (browsing behavior, click identifiers, site interactions)
- Geolocation data (approximate, derived from IP address)
- Payment information (processed by our payment processors; we generally do not receive or store full card numbers)
We do not collect or process “sensitive personal information” (as defined under the CCPA/CPRA) for purposes that would give rise to a right to limit its use. The approximate location we derive from IP address is not precise geolocation, and full payment card numbers are handled by our payment processors rather than stored by us.
Sources: directly from you (when you place an order, sign up, respond to a survey, or contact us); automatically from your device and browsing activity; from our service providers (such as shipping carriers and fraud-prevention providers); and from advertising platforms in connection with ad measurement.
Purposes: as described in Section 4 (How We Use Your Information).
Categories disclosed for business purposes: Identifiers, commercial information, and internet activity — we disclose these to the categories of recipients in Section 6 (ecommerce platform, payment processors, shipping providers, analytics/tracking providers, survey providers, website chat provider, professional advisers).
Categories “sold” or “shared”: Identifiers, commercial information (such as the value and currency of a purchase), and internet/network activity information may be classified as “sold” and/or “shared” with advertising platforms (Meta, Google) for cross-context behavioral advertising, as described in Section 6.
9.2 Your Rights
Subject to certain exceptions and verification, you have the right to:
- Know what personal information we have collected, used, disclosed, and (as applicable) shared about you;
- Delete personal information we have collected from you;
- Correct inaccurate personal information we maintain about you;
- Opt out of the sale or sharing of your personal information, including cross-context behavioral advertising;
- Limit the use or disclosure of sensitive personal information (to the extent we process any);
- Obtain a copy (portability) — receive the personal information you provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit it to another entity without hindrance;
- Non-discrimination — we will not discriminate against you for exercising any of these rights; and
- Appeal a decision we make in response to your request.
To opt out of sale/sharing: use our Your Privacy Choices opt-out page, which takes effect immediately for the browser you use, or email us at info@coody.us with the subject line “Do Not Sell or Share”. Requests sent to us by email are processed within 15 business days of receipt.
To exercise your other rights: contact us using the information in Section 16. We will verify your request using information reasonably necessary to confirm your identity (such as matching order or account details) before processing it.
Authorized agents: You may designate an authorized agent to submit a request on your behalf. We may require proof of the agent’s authorization and may still require you to verify your own identity directly with us.
Response timing: For requests to know, correct, or delete, we will confirm receipt within 10 business days and will generally respond substantively within 45 days, with a possible one-time 45-day extension (90 days total) where reasonably necessary, as permitted by law. If we deny your request in whole or in part, we will explain how you may appeal that decision.
10. Canada
If you are located in Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA), and applicable provincial privacy laws, may apply to our processing of your personal information.
- Access and correction. You may request access to the personal information we hold about you and request that inaccurate information be corrected.
- Consent. We collect, use, and disclose your personal information for the purposes described in this Policy, and, where required by applicable Canadian law, we will obtain your consent (which may be implied by your continued use of the Site for non-sensitive purposes, or express where required).
- Contact. You may direct privacy questions or requests to the contact information in Section 16.
Quebec residents: If you are located in Quebec, Law 25 (the Act Respecting the Protection of Personal Information in the Private Sector) also applies. You have rights to access and correct your personal information, to be informed of any decision based exclusively on automated processing (we do not make decisions about you based exclusively on automated processing — orders flagged for fraud risk are reviewed by a member of our team), and to file a complaint with the Commission d’accès à l’information du Québec.
Person in charge of the protection of personal information. RBM Trading LLC has designated a person in charge of the protection of personal information (our Privacy Officer). You may contact the Privacy Officer by email at info@coody.us, or by mail at RBM Trading LLC, Attn: Privacy Officer, 25 Peterborough Street, Apt 22, Boston, MA 02215, United States.
11. European Economic Area and United Kingdom
We are established in the United States and operate our Site from there. If you are located in the European Economic Area (EEA) or the United Kingdom and the EU General Data Protection Regulation (GDPR) or the UK GDPR applies to our processing of your personal information, the following additional information applies. RBM Trading LLC is the controller of that personal information; our contact details are in Section 16.
11.1 Legal Bases for Processing
We process personal information on the following legal bases:
- Performance of a contract (Art. 6(1)(b)) — to accept, process, ship, and invoice your order, to handle returns and warranty claims, and to respond to your requests about an order.
- Legal obligation (Art. 6(1)(c)) — to meet tax, accounting, customs, and recordkeeping requirements.
- Legitimate interests (Art. 6(1)(f)) — to prevent fraud and secure our Site, to measure and improve the performance of our advertising, and to improve our products and services. Where we rely on legitimate interests, we balance them against your rights and you may object at any time (see 11.2).
- Consent (Art. 6(1)(a)) — for marketing emails and for non-essential cookies and similar technologies where consent is required. You may withdraw your consent at any time; withdrawal does not affect processing carried out before you withdrew it.
11.2 Your Rights
Subject to the conditions and exceptions in applicable law, you have the right to:
- access the personal information we hold about you and obtain a copy of it;
- rectification of inaccurate or incomplete personal information;
- erasure of your personal information (“right to be forgotten”);
- restriction of our processing in certain circumstances;
- data portability — receive the personal information you provided to us in a structured, commonly used, machine-readable format and have it transmitted to another controller where technically feasible;
- object to processing based on our legitimate interests, and to object at any time to processing for direct marketing, including any profiling related to it;
- withdraw consent at any time where our processing is based on consent; and
- not be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you. We do not currently make such decisions.
11.3 How to Exercise Your Rights
Email us using the contact details in Section 16, from the address associated with your order where possible, and include enough information for us to locate your records. We respond within one month of receiving your request. Where a request is complex or you have made several requests, we may extend that period by up to two further months and will tell you why within the first month.
We may need to verify your identity before acting on a request. There is no charge for exercising your rights, unless a request is manifestly unfounded or excessive.
11.4 Retention and Transfers
We retain personal information for the periods described in Section 7. Personal information we collect is processed and stored in the United States, and some of our service providers process it in other countries. Where our service providers transfer personal information out of the EEA or the United Kingdom, they do so under a transfer mechanism available to them — for example an adequacy decision, or the European Commission’s Standard Contractual Clauses together with the UK Addendum where applicable.
11.5 Complaints
If you believe our processing of your personal information infringes applicable data-protection law, you have the right to lodge a complaint with the supervisory authority in the EEA country where you live, work, or where the alleged infringement took place. In the United Kingdom, the supervisory authority is the Information Commissioner’s Office (ICO). We would appreciate the chance to address your concerns first — please contact us using the details in Section 16.
12. International Data Transfers
We are based in the United States, and the personal information we collect is processed and stored in the United States. Some of our service providers may process or store information in other countries, which may have data-protection laws different from those in your own country or region.
Wherever your information is processed, we take steps designed to keep it protected consistent with this Policy and applicable law, including through contractual data-protection commitments with our service providers. By using our Site, you understand that your information may be processed in the United States and in other countries where we or our service providers operate.
13. Security
We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, or disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
14. Children’s Privacy
Our Site is not intended for, and we do not knowingly collect personal information from, individuals under the age of 18. Our products are marketed for purchase by adults. If we learn that we have inadvertently collected personal information from a child under 18, we will take steps to delete it. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.
15. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. We will update the “Effective Date” and version number above when we do. If we make material changes, we will provide notice on this page before the changes take effect. Where required by law, we will obtain your consent before using personal information we previously collected for a materially different purpose.
16. Contact Us
RBM Trading LLC
- Email: info@coody.us
- Phone / WhatsApp: +1 551 295 7817 (WhatsApp)
Mailing address (correspondence only):
RBM Trading LLC
25 Peterborough Street, Apt 22
Boston, MA 02215, United States
Please note: this is a mailing address only. We do not operate a physical store or office at this location.
For questions about cookies and tracking technologies specifically, see our Cookie Policy. To manage your advertising and analytics choices, or to opt out of “sale or sharing” under U.S. state law, visit Your Privacy Choices.
17. Accessibility
We are committed to making our Site usable by everyone, including people with disabilities, and we support the goals of the Americans with Disabilities Act (ADA) and Section 508 of the Rehabilitation Act.
Our standard. We use the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA as our guide. We are not able to guarantee that every page of coody.us currently conforms to these guidelines, and we continue to work toward that goal.
Ongoing effort. Accessibility is treated as part of our regular work on the Site: we review new and updated pages against WCAG 2.1 Level AA, and we fix the barriers we find and the ones you report to us.
Third-party content. Some parts of the shopping experience are provided by third parties and are not built or controlled by us — including the Shopify checkout, the website chat widget, embedded video, and payment provider screens. We cannot guarantee their accessibility, but we will help you complete anything you cannot do yourself (see below) and we raise reported problems with the provider.
Tell us about a barrier. If any part of our Site is difficult or impossible for you to use, or if you need information from it in a different format, contact us and tell us what page you were on and what you were trying to do:
- Email: info@coody.us
- Phone / WhatsApp: +1 551 295 7817 (WhatsApp)
Alternative ways to reach the same result. If you cannot complete something on the Site — browsing products, comparing options, placing an order, tracking a shipment, starting a return or a warranty claim — contact us and we will do it with you and provide the information in a format that works for you. We will help you complete what you were trying to do, and we work on fixing the barrier itself.
Feedback. We welcome your feedback on the accessibility of our Site. If our response does not resolve the problem for you, tell us — it helps us set priorities.
This Privacy Policy works together with our Cookie Policy and Your Privacy Choices page, which together form our complete privacy program for coody.us.