RIGHTBOUND PRIVACY POLICY

Last Updated: December 24th, 2019

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, RightBound (“RightBound” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:

(i) When you make use of, or interact with, our websites https://rightbound.com or https://rightbound.io (“Website”);

(ii) When you contact us thought the Website with an inquiry

(iii) When we receive or collect data regarding our users, to enable them to use our platform.

(iv) When you attend a marketing event and provide us with your personal data

(v) When you exchange business cards with us

(vi) When we acquire your personal data from third-party sources (such as lead-generation companies)

(vii) When we use the personal data of our customers (e.g. contact details)

(viii) When we use the personal data of our resellers, distributors, agents and/or finders (e.g. contact details)

(ix) When we use the personal data of our service providers (e.g. contact details)

(x) When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal data” or “personal information” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

 

1. What information we collect, why we collect it, and how it is used

2. How we protect and retain your personal data

3. How we share your personal data

4. Additional information regarding transfers of personal data

5. Your privacy rights

6. Use by children

7. Interaction with third party products

8. Log files

9. Analytic tools

10. Specific provisions applicable under California privacy law

11. How to contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Specific personal data we collectWhy is the personal data collected and for what purposes?Third parties with whom we share your personal dataRetention periodConsequences of not providing the personal data
When you make use of, or interact with, our Website
Cookies, analytic tools and log filesFor more information, please read our cookies policy https://rightbound.com/cookie-policy· Statistics· Analytics · Google
· Facebook
· LinkedIn
· SendGrid
· Amazon Web Services
For more information, please read our cookies policy https://rightbound.com/cookie-policyCertain Website features may not be available Read more about the purposes of each cookie here https://rightbound.com/cookie-policy
When you contact us (e.g. to address your inquiry)
· Full name
· Company name
· Email address
· Phone number (optional)
· To answer contact you in regards of your inquiry
· To send you marketing/ advertisement communications
· Google
· Facebook
· LinkedIn
· SendGrid
· Amazon Web Services
Until you unsubscribe or we proactively delete the data (usually around 24 months).· Cannot contact you in regards of your inquiry
· Cannot send you marketing/ advertisement communications
When we collect data from our users, while using the RightBound platform
· Full name
· Company name
· Email address
· Ip address
· Location
· To provide you access to our platform and services.· Google
· Facebook
· LinkedIn
· SendGrid
· Amazon Web Services
During the contract term.· Cannot provide you access to our platform and services.
When you attend a marketing event and provide us with your personal data
· Full name
· Email
· Company name
· Registration purposes.
· Marketing purposes.
· Google
· Facebook
· LinkedIn
· SendGrid
· Amazon Web Services
24 months· Cannot attend marketing events.
When you exchange business cards with us
· Full name
· Email
· Role
· Phone Number
· Company name
· Any other data you decide to provide/supply
· Engaging in business discussions
· Marketing
· Google
· Facebook
· LinkedIn
· SendGrid
· Amazon Web Services
24 months· Cannot have business discussions.
When we acquire your personal data from third-party sources
· Full name
· Email
· Phone Number
· Location
· To contact potential members and send them marketing issues· Google
· Facebook
· LinkedIn
· SendGrid
· Amazon Web Services
24 months· Cannot contact you in regards of your inquiry
· Cannot send you marketing/ advertisement communications
When we use the personal data of our customers
· Full name
· Email address
· Company Address
· Company name
· Role/Title
· Phone number
· Location
· Billing address
· Financial information (bank account and/or payment card details)
· To provide our services
· To perform the applicable agreement
· To notify you about changes and updates to our service
· Google
· Facebook
· LinkedIn
· SendGrid
· Amazon Web Services
7 years following termination of the agreement for purposes such as tax purposes- book keeping and record keeping obligations.· Cannot provide the services and\or our products
· Cannot perform the agreement
· Cannot communicate with you
· Cannot send you marketing communications
· Cannot notify you about changes and updates to our service.
When we use the personal data of our resellers, distributors, agents and/or finders
· Full name
· Email address
· Company name
· Phone number
· Any other data you decide to provide/supply
· To contact our service resellers, distributors, agents and/or finders
· To perform the applicable agreement
· Google
· Facebook
· LinkedIn
· SendGrid
· Amazon Web Services
7 years following termination of the agreement for purposes such as tax purposes- book keeping and record keeping obligations.· Cannot communicate with our resellers, distributors, agents and/or finders
· Cannot perform the agreement
When we use the personal data of our service providers
· Full name
· Email address
·  Company name
· Phone number
· Address
· Any other data you decide to provide/supply
· To contact our service providers, suppliers or resellers/distributors/agents· To perform the applicable agreement· Google
· Facebook
· LinkedIn
· SendGrid
· Amazon Web Services
7 years following termination of the agreement for purposes such as tax purposes- book keeping and record keeping obligations.· Cannot contact our service providers
· Cannot perform the agreement
When you interact with us on our social media profiles
· Full name
· Email
· Phone Number
· Social media profile
· Any other data you decide to provide/supply
· To reply and/or respond to your request or question
· To establish a first business connection/discussion
· Google
· Facebook
· LinkedIn
· SendGrid
· Amazon Web Services
24 months· Cannot reply or respond to your request
· Cannot establish a business connection
· Cannot send you marketing communications

Finally, please note that some of the above-mentioned personal data will be used for fraud detection and prevention, and for security purposes. The above-mentioned personal data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION

2.1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

2.2. Retention of your personal data. In addition to the retention periods mentioned above, in some circumstances we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually. Regarding retention of cookies, you can read more in our cookie policy https://rightbound.com/cookie-policy.

3. HOW WE SHARE YOUR PERSONAL DATA 

In addition to the recipients described above, we may share your personal data as follows:

3.1. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

3.2. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;

3.3. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or

3.4. Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

4. ADDITIONAL INFORMATION REGARDING STORAGE OF PERSONAL DATA

Storage: We store data using Amazon Web Services (AWS) – North Virginia – US – subject to the Privacy Shield of AWS.

5. ACCESS & ACCURACY.

To the extent that you do provide us with personal information, we wish to maintain accurate personal information. If you would like to delete or correct any of your other personal information that we may be storing, you may submit an access request by sending an email to privacy@rightbound.io. Your email should include adequate details of your request.

6. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian.

7. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

8. LOG FILES

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

9. ANALYTIC TOOLS

· Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

· Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.

· Mixpanel. We collect personal information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.

· Hotjar. The Website uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.

· Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.

· Google Signals. The Website uses a tool called “Google Signals” to collect information about use of the Website. When we activate Google Signals, some existing Google Analytics features are updated to also include aggregated data from Google users who have turned on “Ads Personalization” (Ads Personalization available at https://support.google.com/ads/answer/2662856/). Audiences that we create in Google Analytics and publish to Google Ads and other Google Marketing Platform advertising products can serve ads in cross device-eligible remarketing campaigns to Google users who have turned on Ads Personalization. Google Analytics collects additional information about users who have turned on Ads Personalization, base across device types and on aggregated data from users who have turned on Ads Personalization. The data is user based rather than session based. The Cross Device reports include only aggregated data. No data for individual users is ever exposed. You can modify your interests, choose whether your Personal Data is used to make ads more relevant to you, and turn on or off certain advertising services in the Ads Personalization link above.

· Facebook Custom Audience

· Lookalike Audience

We reserve the right to remove or add new analytic tools.

10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

10.1. California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to Privacy@Righbound.com. Please note that we will respond to one request per customer each year, unless otherwise required by law.

10.2. Our California Do Not Track Notice:

We may collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services. If you choose to operate your web browser “do not track” signals or any other mechanism that provides consumers the ability to exercise choice regarding the collection of such information, we will abide by your request and stop collecting such information. We may allow third parties such as such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

10.3. Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

10.4. Your privacy rights: Please see Section 5 above.

11. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@rightbound.com