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.
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.
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 email@example.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.
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.
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.
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.
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/.
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.
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.
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 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.
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.
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.
Written communication can be sent to:
633 Folsom Street, 4th Floor
San Francisco, CA 94107
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.
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.
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.
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 so that you can review and/or request the deletion of any or all of such information in accordance with applicable laws and regulations.
Effective Date: JULY 24, 2013