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PRIVACY NOTICE

Last updated November 05, 2021

 

Thank you for choosing to be part of our community at Revenue Growth Architect (“RGA,” “Company,” “I,” “we,” “us,” or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us.

 

This privacy notice describes how we might use your information if you:

  • Visit our website at revenuegrowtharchitect.com
  • Engage with us in other related ways ― including any sales, marketing, or events

 

In this privacy notice, if we refer to:

  • “Website,” we are referring to any website of ours that references or links to this policy
  • “Services,” we are referring to our Website, and other related services, including any sales, marketing, or events

 

The purpose of this privacy notice is to explain to you in the clearest way possible what

information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

 

Please read this privacy notice carefully, as it will help you understand what we do with the information that we collect.

 

TABLE OF CONTENTS

 

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE USE YOUR INFORMATION?
  3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
  4. WHOM WILL YOUR INFORMATION BE SHARED WITH?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  7. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
  8. HOW LONG DO WE KEEP YOUR INFORMATION?
  9. HOW DO WE KEEP YOUR INFORMATION SAFE?
  10. WHAT ARE YOUR PRIVACY RIGHTS?
  11. CONTROLS FOR DO-NOT-TRACK FEATURES
  12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  13. DO WE MAKE UPDATES TO THIS NOTICE?
  14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  15. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

 

1. WHAT INFORMATION DO WE COLLECT?

 

The personal information you disclose to us

 

In Short: We collect personal information that you provide to us.

 

We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and services when you participate in activities on the Website (such as by posting messages in our online forums or entering competitions, contests, or giveaways) or otherwise when you contact us.

 

The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make, and the products and features you use. The personal information we collect may include the following:

 

Personal Information Provided by You. We collect names; phone numbers; email addresses; job titles; usernames; passwords; contact preferences; contact or authentication data; and other similar information.

 

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

Information automatically collected

 

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.

 

We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

 

Like many businesses, we also collect information through cookies and similar

technologies.

 

The information we collect includes:

 

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings, and information about your activity on the Website (such as the date/time stamps associated with your usage, pages, and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).

 

Device Data. We collect device data such as information about your computer, phone, tablet, or other devices you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system, and system configuration information.

 

Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt-out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note, however, if you choose to opt-out, you may not be able to use certain aspects of the Services.

 

Information collected from other sources

 

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

 

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

 

2. HOW DO WE USE YOUR INFORMATION?

 

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

 

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

 

In legal terms, we are generally the “data controller” under European data protection laws since we determine the means and/or purposes of the data processing we perform. However, if you are a business customer with whom we have entered into a data processing agreement for the provision of corporate services to you, then you would be the “data controller” and we would be the “data processor” under European data protection laws since we would be processing data on your behalf in accordance with your instructions.

 

We use the information we collect or receive:

 

  • To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
  • To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update or delete your testimonial, please contact us and be sure to include your name, testimonial location, and contact information.
  • Request feedback. We may use your information to request feedback and to contact you about your use of our Website.
  • To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
  • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
  • To send administrative information to you. We may use your personal information to send you the product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
  • To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements, or in connection with our contract.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.
  • Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.
  • To deliver and facilitate the delivery of services to the user. We may use your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
  • To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing, or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below).
  • Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
  • For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improving our
  • Website, products, marketing, and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end-users and does not include personal information.

 

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

 

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

 

We may process or share your data that we hold based on the following legal basis:

 

  • Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

 

More specifically, we may need to process your data or share your personal information in the following situations:

 

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Place API). To find out more about Google’s Privacy Policy, please refer to this link. We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. A full list of what we use the information for can be found in this section and in the previous section titled “HOW DO WE USE YOUR INFORMATION?”. We obtain and store on your device (‘cache’) your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use to store and access cookies and other information on your devices.
  • Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages, or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protecting the data they hold on our behalf and to retaining it for the period we instruct.
  • Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit or use the Website. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

 

4. WHOM WILL YOUR INFORMATION BE SHARED WITH?

 

In Short: We only share information with the following categories of third parties.

 

We only share and disclose your information with the following categories of third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.

 

  • Ad Networks
  • Affiliate Marketing Programs
  • Performance Monitoring Tools

 

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

 

In Short: We may use cookies and other tracking technologies to collect and store your information.

 

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

 

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

 

In Short: We may transfer, store, and process your information in countries other than your own.

 

Our servers are located in multiple countries. If you are accessing our Website from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in and other countries.

 

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

 

European Commission’s Standard Contractual Clauses:

 

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

 

EU-U.S. and Swiss-U.S. Privacy Shield Frameworks:

 

RGA complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU), the UK, and Switzerland to the United States. Although Privacy Shield is no longer considered a valid transfer mechanism for the purposes of EU and Swiss data protection law, in light of the judgment of the Court of Justice of the European Union in Case C-311/18 and the opinion of the Federal Data Protection and Information Commissioner of Switzerland dated 8 September 2020, RGA will continue to comply with the principles of the EU U.S. and Swiss-U.S. Privacy Shield Frameworks. To learn more about the Privacy Shield program, please visit www.privacyshield.gov.

 

RGA adheres to and complies with the Privacy Shield Principles when processing personal information from the EU, UK, or Switzerland. If we have received your personal information in the United States and subsequently transfer that information to a third party acting as our agent, and such third party agent processes your personal information in a manner inconsistent with the Privacy Shield Principles, we will remain liable unless we can prove we are not responsible for the event giving rise to the damage.

 

With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, RGA is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”). In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

If you have any questions or concerns relating to RGA’s Privacy Shield certification, please write to us at the contact details below. We commit to resolving any complaints or disputes about our collection and use of your personal information under Privacy Shield. However, if you have an unresolved complaint in connection with our Certification, please contact us.

 

In limited situations, EU, UK, and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

 

Please be sure to review the following sections of this Privacy Notice for additional details relevant to RGA’s participation in the EU-U.S. and Swiss-U.S. Privacy Shield:

 

  • WHAT INFORMATION DO WE COLLECT? To learn more about the types of personal data RGA collects.
  • HOW DO WE USE YOUR INFORMATION? To learn more about the purposes for which RGA collects and uses personal information about you.
  • WILL YOUR INFORMATION BE SHARED WITH ANYONE? To learn more about the type or identity of third parties to which RGA discloses personal information and the purposes for which we do so.
  • WHAT ARE YOUR PRIVACY RIGHTS? To learn more about the right of individuals to access their personal data.

 

7. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

 

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our Website.

 

The Website may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services, or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Website. You should review the policies of such third parties and contact them directly to respond to your questions.

 

8. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

 

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

 

10. WHAT ARE YOUR PRIVACY RIGHTS?

 

In Short: In some regions, such as the European Economic Area (EEA) and United

Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

 

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

 

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

 

Account Information

 

If you would at any time like to review or change the information in your account or terminate your account, you can:

 

  • Log in to your account settings and update your user account.
  • Contact us using the contact information provided.

 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with applicable legal requirements.

 

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt-out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/.

 

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example, to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

 

  • Access your account settings and update your preferences.
  • Contact us using the contact information provided.

 

11. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

 

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

 

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding the calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

 

If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request the removal of unwanted data that you publicly post on the Website. To request the removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

 

CCPA Privacy Notice

 

The California Code of Regulations defines a “resident” as:

 

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

Category Examples Collected
A. Identifiers

Contact details, such as real name, alias, postal address, telephone, or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

YES

B. Personal information categories listed in the California Customer Records statute

Name, contact information, education, employment, employment history, and financial information

YES

C. Protected classification characteristics under California or federal law

Gender and date of birth

YES
D. Commercial information

Transaction information, purchase history, financial details, and payment information

YES
E. Biometric information

Fingerprints and voiceprints

YES

F. Internet or other similar network activity

Bowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

YES
G. Geolocation data Device location YES

H. Audio, electronic, visual, thermal, olfactory, or similar information

Images and audio, video, or call recordings created in connection with our business activities

YES

I. Professional or employment-related information

Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us

YES
J. Education Information Student records and directory information YES

K. Inferences drawn from other personal information

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

YES

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:

 

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

 

How do we use and share your personal information?

 

RGA collects and shares your personal information through:

 

  • Targeting cookies/Marketing cookies
  • Social media cookies
  • Beacons/Pixels/Tags
  • Click redirects
  • Social media plugins. We may use social media features, such as a ‘Like’ button, and widgets, such as a ‘Share’ button on our Website. Such features may process your Internet Protocol (IP) address and track which page you are visiting on our Website. We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform and you interact with a widget or button belonging to that social media platform, this information may be recorded to your profile of such social media platform. To avoid this, you should log out from that social media platform before accessing or using the Website. Social media features and widgets may be hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy notices of the companies that provide them. By clicking on one of these buttons, you agree to the use of this plugin and consequently the transfer of personal information to the corresponding social media service. We have no control over the essence and extent of these transmitted data as well as their additional processing.

 

More information about our data collection and sharing practices can be found in this privacy notice and our Cookie Notice: policy.com.

 

You can opt-out from the selling of your personal information by disabling cookies in Cookie Preference Settings and clicking on the Do Not Sell My Personal Information link on our homepage.

 

You may contact us or by referring to the contact details at the bottom of this document.

 

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

 

Will your information be shared with anyone else?

 

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

 

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

 

RGA has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

 

  • Category A. Identifiers, such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
  • Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.
  • Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
  • Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.
  • Category E. Biometric information, such as fingerprints and voiceprints.
  • Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
  • Category G. Geolocation data, such as device location.
  • Category H. Audio, electronic, visual, and similar information, such as images and audio, video or call recordings created in connection with our business activities.
  • Category I. Professional or employment-related information, such as business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us.
  • Category J. Education information, such as student records and directory information.
  • Category K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

 

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHO WILL YOUR INFORMATION BE SHARED WITH?”.

 

RGA has sold the following categories of personal information to third parties in the preceding twelve (12) months:

 

  • Category A. Identifiers, such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
  • Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.
  • Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
  • Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.
  • Category E. Biometric information, such as fingerprints and voiceprints.
  • Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
  • Category G. Geolocation data, such as device location.
  • Category H. Audio, electronic, visual, and similar information, such as images and audio, video or call recordings created in connection with our business activities.
  • Category I. Professional or employment-related information, such as business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us.
  • Category J. Education information, such as student records and directory information.
  • Category K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

 

The categories of third parties to whom we sold personal information are:

 

Your rights with respect to your personal data

 

Right to request deletion of the data – Request to delete

 

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

 

Right to be informed – Request to know

 

Depending on the circumstances, you have a right to know:

 

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell your personal information to third parties;
  • the categories of personal information that we sold or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  • the business or commercial purpose for collecting or selling personal information.

 

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

 

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

 

We will not discriminate against you if you exercise your privacy rights.

 

Verification process

 

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

 

We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

 

Other privacy rights

 

  • you may object to the processing of your personal data.
  • you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data.
  • you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

 

To exercise these rights, you can contact us or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

 

13. DO WE MAKE UPDATES TO THIS NOTICE?

 

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

 

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by contacting us.

 

If you are a resident in the European Economic Area or the United Kingdom, the “data controller” of your personal information is RGA. RGA has appointed an executive to be its representative in the EEA. You can contact them here.

 

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us.