Except as explicitly set forth herein, RichRelevance, Inc. (“RichRelevance”, “We”, “Us” OR “Our”) does not collect your Personal Information through our Services. In limited instances, certain of our Customers (as defined herein) provide us with their consumer end users’ email addresses so that we can personalize their email 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 we do collect, 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 may respond to inquiries you make.
EU-U.S. and Swiss-U.S. Privacy Shield
RichRelevance participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. RichRelevance is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on the Privacy Shield Frameworks, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.
RichRelevance is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. RichRelevance complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, RichRelevance is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. 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.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please submit a complaint directly to your local DPA or the Swiss Federal Data Protection and Information Commissioner.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Personal Data Transfers from Europe to the United States
With respect to any RichRelevance restricted transfers of Personal Data from the EU, EEA, or UK to RichRelevance’s facilities in the United States requiring the use of an approved transfer mechanism, up until July 2020, RichRelevance utilized the EU-U.S. Privacy Shield Framework self-certification for such purpose. While RichRelevance remains committed to handling all such Personal Data in accordance with such framework, in light of the fact that, in July 2020, the Court of Justice of the European Union invalidated portions of the EU-Privacy Shield Framework, and until such time as a new Privacy Shield framework is secured that is deemed adequate by the European Union, RichRelevance (and Partner) is committed to complying with the Standard Contractual Clauses (“SCCs”). In the event of any conflict between the SCCs and Privacy Shield, the SCCs shall govern.
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, the right to be forgotten, data portability, and privacy by design.
California Consumer Privacy Act (CCPA)
RichRelevance also complies with California Consumer Privacy Act (“CCPA”) as approved on August 14, 2020. RichRelevance believes and supports the five general rights for personal information 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 such 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 their 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.
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. 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.
EXCEPT FOR THE LIMITED COLLECTION AND USE OF EMAIL ADDRESSES, WE DO NOT COLLECT PERSONAL INFORMATION THROUGH OUR SERVICES
Cookies and Tracking Technology
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 Services. We do not link this automatically collected data to other information we collect about you.
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 set your 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.
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.
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 firstname.lastname@example.org. 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 and Other Sources of 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
Links To 3rd Party Sites
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 email@example.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
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 firstname.lastname@example.org.
Some of our pages utilize framing techniques to serve content to 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 email@example.com
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 firstname.lastname@example.org. 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
49 Stevenson Street, Suite 950, San Francisco, CA 94105
Effective Date: December 21, 2020
RichRelevance products are licensed under U.S. Patent No. 6,330,592.