Last Updated: June 22, 2020
HOW WE COLLECT AND USE INFORMATION
INFORMATION YOU PROVIDE TO US
- Personal Information: We may ask you for, or you may choose to provide information, such as age or gender. This information may identify, relate to, describe, reference, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include: (a) Publicly available information from government records; (b) Deidentified or aggregated consumer information; or (c) Information excluded from the California Consumer Protection Act’s scope, like: (i) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; (ii) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
- Other Information: You may provide other information directly to us. For example, we may collect information when you fill out a form, interact with the Services, communicate with us via third-party social media sites, request support or otherwise communicate with us.
OTHER INFORMATION WE COLLECT WHEN YOU USE THE SERVICES
- Location Information: We may collect location information. If you consent to the collection of location information (e.g. if you permit your mobile device to send us your latitude and longitude), we may collect and use this information both while you are directly using the Services and in the “background” (i.e. at times when you are not directly using the Services), so that we can tailor your interactions and experiences with the Services. We may use your IP address or information about the WiFi SSID from which you access the Services to determine an approximate geographic location for your device.
- Usage Information: We may collect information about your use of the Services, including access times, pages and posts viewed, and other information about your interactions with us, the Services and other users. We may use this information to, among other things, personalize your experience, provide and improve the Services, and monitor and analyze use of the Services.
- Device Information: We may collect information about the device you use to access our Services, which may include the hardware model, operating system and version, browser type and language, IP address, unique device identifiers and mobile network information. Among other things, we may use this information to customize the Service for your device, to provide customer service and support, to deliver the products and services you request, to deliver notifications, for user safety, and for analytics and authentication.
- Log Information: We may collect information in our log files when you use the Services. This includes, among other things, your browser and device type, language, access times, pages viewed, your IP address, and the URL you visited before navigating to our websites. We use log information to provide, understand, and improve our Services.
- In particular, we may collect the following categories of personal information from our users: Identifiers (i.e. a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, etc.), Protected classification characteristics under California or federal law (i.e. age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, etc.), Internet or other similar network activity (i.e. browsing history, search history, information on a consumer’s interaction with a website, application, advertisement, etc), Geolocation data (i.e. physical location or movements, etc.).
COLLECTION AND USE OF SPECIAL CATEGORIES OF PERSONAL DATA
The following special categories of personal data are may be considered sensitive under the laws of your jurisdiction and may receive special protection:
- Racial or ethnic origin.
- Political opinions.
- Religious or philosophical beliefs.
- Trade union membership.
- Genetic data.
- Biometric data.
- Data concerning health.
- Data concerning sex life or sexual orientation.
- Data relating to criminal convictions or offenses.
HOW WE SHARE INFORMATION
When you use the Services, certain information may be shared with other users and the public. For example:
- Any post in the Services is public and, as a result, others may be able to see the text and image contents of your post and the geographic location in which you post.
- If you post any User Content to the Services, other users may be able to see certain information related to your location. For example, other users may be able to see whether you are or were within a certain proximity of their current location or if you frequent similar locations.
- If you invite others to try RU^ via SMS, email or otherwise, those individuals may see your name, phone number, email address or other contact information.
- With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
- If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of RU^ or others;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
- Between and among RU^, and its current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
- If we have a good faith belief that disclosing the information is necessary to comply with a law, regulation, legal process, or governmental request; and
- With your consent or at your direction.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
SOCIAL SHARING FEATURES
The Services may offer social sharing features and other integrated tools, which let you share posts with other media. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
ADVERTISING AND ANALYTICS SERVICES
Your posts remain public, if they were posted publicly, so long as you or we do not delete them from the Services. You may choose to delete your individual posts at any time and we will then remove them from the Services. However, it is important to note that your deleted posts may remain in storage in our systems for a limited period of time for legal, business, safety, or system backup reasons, and they may remain accessible in cached and archived pages of the Services or elsewhere if others have chosen to copy or save them. Search engines and other sites may also index and cache content on our Services. You may have to contact these third-party sites or search engines directly to delete your cached information, subject to their policies and procedures.
When you first download or open any of our website or access certain features of the Services, you may be asked to consent to the collection of location information from your mobile device or platform. If you consent to the collection of this information but later wish to withdraw your consent, you may do so.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
WHERE INFORMATION IS PROCESSED
RU^ is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.
PRIVACY NOTICE UNDER GDPR AND FOR CALIFORNIA RESIDENTS
This Privacy Notice supplements the information contained in this privacy notice and applies solely to all visitors, users, and others who reside in the State of California or reside in an area that is subject to E.U.’s General Data Protection Regulation (“GDPR”) (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some of its requirements.
YOUR RIGHTS AND CHOICES
The CCPA and GDPR provide certain consumers with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.
ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
DELETION REQUEST RIGHTS
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech or ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by Emailing us at: firstname.lastname@example.org.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Anyone can make a verifiable consumer request with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
RESPONSE TIMING AND FORMAT
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
PERSONAL INFORMATION SALES OPT-OUT AND OPT-IN RIGHTS
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing us at email@example.com .
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by: emailing us at firstname.lastname@example.org.
Anyone may exercise their opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
OTHER CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that 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 contact us at:
Attn: RU^ – Privacy Department
575 E 4th St. Winston Salem, NC 27101
CROSS-BORDER DATA TRANSFERS
Where permitted by applicable law, we may transfer the personal data we collect about you to other jurisdictions other than where you reside that may not be deemed to provide the same level of data protection as your home country for the purposes set out in this Privacy Notice.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:
Attn: RU^ – Privacy Department
575 E 4th St. Winston Salem, NC 27101