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Privacy

RichRelevance Privacy Policy

Your privacy is very important to us.  This Privacy Policy explains how we collect, use and disclose your information through our recommendation, personalization and advertising retargeting services (“Services”) and through our corporate website located at www.richrelevance.com. If you have any questions, please do not hesitate to contact us at privacy@richrelevance.com. To opt out of our behavioral advertising product, click here.

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 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 Non-Personally Identifiable Information 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.

RichRelevance has been awarded TRUSTe’s Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe’s program requirements including transparency, accountability and choice regarding the collection and use of your Personal Information (as defined below).

The TRUSTe program does not cover information that may be collected through downloadable software.  The TRUSTe program covers only information that is collected through this Web site, www.richrelevance.com.

TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@richrelevance.com. If you are not satisfied with our response you can contact TRUSTe here.

We self-certify compliance with:

RichRelevance complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.  RichRelevance has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view RichRelevance’s certification, please visit http://www.export.gov/safeharbor/.   If you have questions or concerns regarding this statement, you should first contact RichRelevance by email at privacy@richrelevance.com.

As part of our participation in the safe harbor, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have any complaints regarding our compliance with the Safe Harbor you should first contact us (as provided above). If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet here, fax to 415-520-3420, or mail to TRUSTe Safe Harbor Complaints Dept., click for mailing address. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe’s dispute resolution process, click here or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English. For human resources data we have agreed to cooperate with Data Protection Authorities.

Information Collection and Use

Non-Personally Identifiable Information (“NPII”) 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 NPII is collected from your browser or directly from our Customers and includes non-personally identifiable information such as your IP address, a unique Customer ID number, the date and time of use of our Services, and your activity on Customers’ websites and on third party websites that display advertisements of Customers’ products and services (“Publishers”). We use NPII to provide you Customer product and service recommendations and advertisements either on Customer and Publisher websites or through Customer emails. In the future we may decide to use NPII 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 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 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. EXCEPT FOR THE LIMITED COLLECTION AND USE OF EMAIL ADDRESSES, WE DO NOT COLLECT PERSONAL INFORMATION THROUGH OUR SERVICES.

Cookies and Pixel Tags

“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 accessed. We use cookies in the delivery of recommendations and advertisements on Customers’ and Publishers’ websites. 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 websites through more personalized recommendations and advertisements. 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.

Pixel tags are small strings of code that provide a method for delivering a graphic image on a Web page or other document. Pixel tags allow the third party who serves the pixel tag to set cookies on your browser and obtain NPII. We allow third party advertising exchanges to insert pixel tags in product recommendations we place on Customers’ websites so that we may advertise those Customers’ products and services on Publishers’ websites. 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. For more information about how to “opt-out” of cookies from third party advertising exchanges, please click here.

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 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.

Advertising Opt Out

You may also opt out of our use of your NPII to determine what advertisements to show you on Publishers’ websites by clicking on the button below. Opting out will prevent us from providing you personalized advertisements based on your preferences. However, we will continue to collect your NPII as described above in “Information Collection and Use.” If you choose to opt-out by clicking on this button you will receive what is referred to as a “persistent cookie” that tells us not to recognize your browser. We must maintain the cookie on your browser in order to recognize you as having opted-out. You must opt-out again if you clear that cookie from your browser, use a different internet browser, or use a new computer to access the internet.

In our Customer agreements, we use commercially reasonable efforts to require that Customers, as data controllers (in the EU context), add statements or clauses to their privacy policies specifically describing their use of NPII for behavioral advertising. Further, we use commercially reasonable efforts to require that each Customer provide its end user consumers with information regarding the ability to opt-out of such use of the NPII as we have provided herein. RichRelevance is a member of the Network Advertising Initiative. You can learn more about the Network Advertising Initiative, as well as opt-out of our behavioral advertising product by clicking here.

RichRelevance also adheres to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising http://www.aboutads.info/.

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

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.

Security/Retention

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of information we process, including your NPII. 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 your NPII only for so long as it remains relevant to providing you with product recommendations and advertisements or to the extent permitted by law. This retention period may be indefinite. We retain your NPII for use in connection with our RichAds retargeting solution only for so long as it remains relevant to providing you with product recommendations and advertisements. This retention period will not exceed 2 years. 
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

This 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.

Questions

If you have questions about this Privacy Policy or believe that RichRelevance has not adhered to a term or terms of this Privacy Policy, please contact us by email at privacy@richrelevance.com.

Written communication can be sent to:

RichRelevance, Inc.,
633 Folsom Street, 4th Floor
San Francisco, CA 94107

Website and Other Sources of Personal Information

Personal Information

The 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, and LeadLander.

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.

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.

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.

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. 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

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 so that you can review and/or request the deletion of any or all of such information in accordance with applicable laws and regulations.

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.

Effective Date:  JULY 24, 2013

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