Privacy Policy

Your privacy is very important to us. This Privacy Policy applies to RichRelevance Inc. and its Affiliates (collectively, “RichRelevance”, “We”, “Us”, or “Our”), www.richrelevance.com and Services owned and operated by RichRelevance, Inc. This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your personal information, as well as your rights in determining what we do with the information that we collect or hold about you. This Privacy Policy describes how we collect, use and disclose your information through our personalization services, including without limitation our Recommend, Engage, Find, Discover and Build services predecessor and successor services (“Services”) and through our corporate website located at www.richrelevance.com. It also describes the choices available to you regarding your access to, and how to update and correct your personal information. If you have any questions, please do not hesitate to contact us at privacy@richrelevance.com. For the purpose of this Privacy Policy “Affiliates” shall mean any entity that directly or indirectly controls, is controlled by, or is under common control with the party, including subsidiaries, parent companies, and related companies.

RichRelevance is responsible for the processing of your Personal Information when you interact with OUR website, service, products, mobile applications; employees/applicants/agents or careers portal; events/conferences/offices; cloud-based applications/platforms; other technologies described in this Privacy Policy, and any other sites or services under our control where this Privacy Policy is displayed.

Certain of our Customers (as defined herein) provide us with their consumer end users’ email addresses so that we can personalize their e-communications to you; however, we make no use of such email addresses other than as instructed by such Customers. Furthermore, none of the Service Data collected, individually or grouped together, can be traced back to you. We do allow you to provide certain non-financial personal information on our website so that we can respond to inquiries you make.

Data Privacy Framework

RichRelevance complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. RichRelevance has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) under the UK Extension to the EU-U.S. DPF. RichRelevance has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

RichRelevance is responsible for the processing of personal data it receives, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf. RichRelevance complies with the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over RichRelevance’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, RichRelevance may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, RichRelevance commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.trustarc.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

For complaints regarding EU-U.S. DPF, the UK Extension to the EU-U.S DPF, and Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction- dpf?tabset-35584=2.

General Data Protection Regulation (GDPR)

RichRelevance also complies with European Union (“EU”) regulations regarding the processing and movement of personal data including the General Data Protection Regulation 2016/679 (the “GDPR”). RichRelevance believes privacy is a human right and supports the foundations of the GDPR including breach notification, the right to access, right to be forgotten, data portability, and privacy by design. For Personal Data transfers outside the European Economic Area (EEA), RichRelevance ensures compliance with GDPR through appropriate safeguards, such as the use of the European Commission’s Standard Contractual Clauses (SCCs).

California Consumer Privacy Act (CCPA)

RichRelevance also complies with California Consumer Privacy Act (“CCPA”) and any relevant updates or amendments to it. RichRelevance believes and supports the five general personal information rights under the CCPA, including right to know what information is being collected, the right to know if information is being sold/disclosed and to opt out of sale, the right to access personal information collected, the right to have such personal information collected be deleted, the right of non-discrimination for exercising rights under the CCPA.

Brazil National Law (LGPD)

RichRelevance also complies with the national law (LGPD) enacted by Brazil which is similar to the GDPR but with its own Brazil-specific requirements.

Our Services

Information Collection and Use

“Services Data” is data collected by us in order to allow us to provide the Services to you and to our customers that have entered into an agreement with us to provide Services (“Customers”). The Services Data is collected from your browser or directly from our Customers and includes information such as your IP address (which in certain instances may be truncated or rendered pseudononymous), a unique Customer ID number, the date and time of use of our Services, and your activity on Customers’ websites. We use Services Data to provide you Customer product and service recommendations and advertisements either on Customer websites or through Customer emails. In the future, we may decide to use Services Data to provide you such recommendations and advertisements through other forms of digital distribution.

“Personal Information” means individually identifiable information that would allow a party to identify you or to contact you (online or offline). This type of information may include, for example, your name, address, telephone number, or email address and other details as outlined in the “Types of Personal Information” section below. Certain Customers of ours (such as our retail business partners) provide us email addresses that they have obtained from you with your consent for the sole purpose of enabling us to personalize emails from those Customers to you using our product recommendation services. Accordingly, we may transfer personal information to companies that help us provide our service but we will not disclose such Personal Information to any third party unless specifically and rightfully instructed or directed to do so by Customer, and will not otherwise share, disclose, rent, or sell any such Personal Information except as requested or directed by Customer or as we believe may be required by law or to otherwise protect our legal rights. Transfers to subsequent third parties, if any, are covered by the service agreements with our Customers. If you would no longer like to be contacted by one of our Customers that use our Services, please contact our Customer that you interact with directly.

We may share Personal Information with third-party vendors to help us provide our services. For international data transfers outside the European Economic Area (EEA), we use legally approved safeguards to ensure your information is protected. These safeguards include the use of the European Commission’s Standard Contractual Clauses (SCCs) or contractual obligations requiring vendors to adhere to the same data protection standards as outlined in the SCCs. While we aim to engage with vendors who adhere to such safeguards, not all current or future vendors may use SCCs. In such cases, we will evaluate their compliance with data protection laws and implement necessary agreements to ensure your data is handled appropriately.

If you would no longer like to be contacted by one of our Customers that use our Services, please contact our Customer that you interact with directly.

Types of Personal Information

We collect and process the following types of personal information:

1. Identity and Role Information: Name, username, login credentials, job title, company name, and user preferences.
2. Contact Details: Email, mailing/work address, telephone numbers, device identifiers, and IP addresses.
3. Location Data: Precise geolocation and general IP-based location.
4. Usage Data: Interactions with our websites, apps, and services, such as visits, clicks, and downloads.
5. Server Logs: Automatically collected information, including IP addresses, browser type, timestamps, and viewed files.
6. Customer Service Data: Details provided during support interactions or newsletter subscriptions.
7. CRM Data: Customer relationship details, including sales, product usage, and rankings.
8. Network Security Information: Data for fraud prevention and cybersecurity, including network traffic and identifiers

This information supports our services, ensures security, and complies with legal requirements.

EXCEPT FOR THE LIMITED COLLECTION AND USE OF NAME, COMPANY NAME, PHONE NUMBER and EMAIL ADDRESSES, WE DO NOT COLLECT PERSONAL INFORMATION THROUGH OUR SERVICES

Cookies and Tracking Technology

Cookies or similar technologies are used by RichRelevance and third-party advertising exchanges that we use so that we may advertise our Customers’ products and Customers’ websites. “Cookies” are small data files that contain a string of characters that are sent to your computer browser from our servers when our Services are used. Cookies allow us to save your preference information to improve the quality of our Services and to allow Customers to offer you a better experience on their website with personalized recommendations and advertisements. These technologies are also used in analyzing trends, administering the site, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual or aggregated basis. The information we collect from cookies is only used in conjunction with your use of Services and is not shared by us with any third party. RICHRELEVANCE CANNOT AND DOES NOT USE COOKIES TO DETERMINE ANY INDIVIDUAL’S ACTUAL IDENTITY.

We gather certain information automatically from our customers’ websites and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site. We do not link this automatically collected data to other information we collect about you.

Disable Cookies

You have the right to decide whether or not to accept cookies. By default, most Web browsers are set up to accept cookies. If you prefer not to receive cookies, you can use the browser to provide a warning and/or refuse the cookie. You can also refuse all cookies by turning them off in the browser. At any time you can delete cookies from your browser. If you disable cookies, please note that we may be prevented from providing personalized recommendations and advertisements to you.

Disclosure of Aggregated Information

We may disclose aggregated information about the use of Services to business partners, prospective investors, and others. Additionally, we may produce industry-standard traffic reports for assessing use of Services. This information cannot be traced back to you personally.

Use of Personal Information

We use the personal information collected or obtained for the following purposes:

1. Service Delivery and Improvement: To provide, operate, and enhance the products and services you request or purchase.
2. Communication: To communicate with you regarding our offerings, services, and updates.
3. Authentication and Security: To authenticate users, prevent fraud, and detect misuse of our sites and services.
4. Performance Evaluation: To evaluate and measure the performance of our sites and services.
5. Legal Compliance: To comply with applicable laws, regulations, and legal obligations.
6. Marketing and Advertising: To provide personalized experiences, targeted advertising, and direct marketing about relevant products and services.
7. Customer Engagement: To provide customer support, respond to inquiries, gather testimonials, and conduct surveys for audience insights.
8. Third-Party Services: To offer co-branded services or features, where your information may be shared with third parties with your consent, governed by their privacy policies.
9. Promotional Activities: To manage participation in loyalty programs, sweepstakes, contests, and promotional events.
10. Analytics and Optimization: To analyze site and service usage, optimize resources, and discover trends or segments within our audience.
11. Corporate Transactions: To facilitate mergers, asset sales, or other corporate changes.
12. Policy Enforcement: To investigate potential violations of our policies, terms of use, or legal rights.
13. Eligibility Verification: To verify eligibility for specific programs or benefits.
14. Social Media and Sharing: To enable social media sharing features and functionalities.
15. Other Purposes: To use your information in other ways consistent with your consent.

Sharing of Personal Information

We may share your personal information with:

1. Service Providers: Trusted vendors, contractors, and suppliers supporting our operations.
2. Affiliates: Our affiliates for business operations and service enhancements.
3. Third-Party Partners: With your consent, for co-branded services or features governed by their privacy policies.
4. Corporate Transactions: During mergers, acquisitions, or other significant corporate changes.

Information Gathered by Our Customers or Other Third Parties

Except for limited instances described above where Customers provide email addresses to us, RichRelevance does not come in contact with, and specifically disclaims any association with, any Personal Information collected by Customers from their consumer end users. Customers may include usernames in the user identification tags that they pass to us, but we have no control over such tags and use this information only as a database identifier. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate Personal Information should direct his query to our Customer (the data controller). If requested to remove Personal Information we will respond within a reasonable timeframe.

RichRelevance respects your control over your information and, upon request, we will confirm whether we hold or are processing information that we have collected from you. Depending on the applicable laws in your jurisdiction, you may also have the right to access, amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you with an explanation. In order to make such a request, please contact us using the information in the contact us section in this privacy notice.

Security/Retention

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of information we process. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

We retain Services Data only for so long as it remains relevant to providing you with product recommendations and advertisements on our Customers’ Websites or to the extent permitted by law. Our collection of Personal Information is limited to the receipt of email addresses from a few of our Customers. We will retain this Personal Information for as long as needed to provide services to our Customers. If you wish that we no longer use your Personal Information to provide you services contact us at privacy@richrelevance.com. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes to RichRelevance’s Corporate Structure

If RichRelevance is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via a prominent notice on our Website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

Changes and Updates

We may change or update this policy. When we do, we will also revise the Effective Date at the end of this policy. If we make any material changes to this policy, we will notify you by means of a notice on our Website prior to the change becoming effective. We encourage you to review this policy periodically to stay informed about our collection, use and disclosure of personal information.

International Visitors and Customers

Our Website is hosted in the United States, and we provide our services from the United States. If you use our services from the European Union (or visit a Customer who uses our services in the European Union), please note that your data will be transferred to our servers in the United States. While the United States does not have data protection laws that are equivalent to those in the European Union, we will at all times protect any data we collect in accordance with this Privacy Policy.

Our Website and Other Sources of Personal Information

Personal Information

Our Website requires a minimal amount of Personal Information to maintain account information and communicate with Customers and potential Customers regarding use of Services. Additional information may be needed in the future by us or by partners in order to provide Customers with additional products and services. We limit access to specific contact information internally to only those employees and contractors who design and maintain the system information stores or who have a reasonable need to come in contact with and make use of such information for account purposes.

Third Parties/Advertisers and Your Information

We allow a third party to insert pixel tags on our Website so that we may advertise Services to Customers and potential Customers after they have left the Website. These third parties can write and read their own cookies on your computer, just as if you had requested a web page from their websites. We are not responsible for, and do not have any control over, the privacy practices or the content of such third parties. We encourage users to read the privacy policy of our third party service providers here: Google, Marketo. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Links To 3rd Party Sites

Our Site includes links to other Web sites whose privacy practices may differ from those of RichRelevance. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Blog

If you post comments to the Blog pages on this Website, you should be aware that any Personal Information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in your comments. To request removal of your Personal Information from our blog, contact us at privacy@richrelevance.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why. Alternatively, if you used a third party application to post such information, you can remove it, by either logging into the said application and removing the information or by contacting the appropriate third party application.

Social Media Widgets

Our web site includes social media features, such as the Facebook Like button and widgets, such as the ShareThis button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our web site. Your interactions with these features are governed by the privacy policy of the company providing it.

Testimonials

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@richrelevance.com.

Frames

Some of our pages utilize framing techniques to serve content to and from our partners while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties and not to www.richrelevance.com.

Personal Information Collected Under Other Circumstances

RichRelevance may collect and retain Personal Information from you under other circumstances, such as any communications regarding job postings, service improvements, or support issues. RichRelevance will use the same measure of care with this information as we provide to our own private information and office communications.

We may provide your personal information to companies that provide services to help us with our business activities such as marketing our services or managing employee recruitment efforts. These companies are authorized to use your personal information only as necessary to provide these services to us.

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can contact us at privacy@richrelevance.com

Disclosure

RichRelevance will not rent, sell, or disclose your Personal Information to third parties. If you submit your contact information to RichRelevance, we may send you certain communications relating to our products and services or this Privacy Policy.

RichRelevance will only share Personal Information with outside parties in ways that are described in this Privacy Policy.

In certain situations, RichRelevance may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Review of Personal Information

Upon request RichRelevance will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. If you wish to access your Personal Information, please send an email to privacy@richrelevance.com. We will provide you with access to your Personal Information collected on or through our Website so that you can review, correct, update and/or request the deletion of any or all of such information in accordance with applicable laws and regulations. We will respond to your request to access within 30 days.

Children’s Online Privacy

Children under 13 are not eligible to use the Website and so this privacy policy makes no provision for children’s use of the Website.

Contact Us

If you have questions or concerns about this privacy policy, please contact us through the information below: