Effective July 1, 2020
2. The Personal Data We Collect and Use
2.1. INFORMATION COLLECTED FROM YOU
In visiting our Site or conducting business with us, you may submit data about you directly to us for several reasons, such as interest in:
- Learning more about our products and services;
- Accessing our proprietary content;
- Registering for webinars, training programs, courses, or other events;
- Subscribing to newsletters, updates, or requesting additional information; and/or
- Applying for a job.
That information or combination of data or more sensitive information may be used to identify you (together “Personal Data”). Most of the Personal Data we receive from you may be publicly available but will be protected as set forth below.
If you request information or materials – we collect the following Personal Data as provided by you: your first and last name, your telephone number, and your email address. In certain instances, we may collect additional information such as your place of employment, marketing budgets, and revenue.
If you submit an inquiry or download materials related to our services – we may also request information about your place of employment including the name of the organization, your job title, the organization’s Site URL, the organization’s AdWords spend figures, and other information about the company’s interest in and approach to the types of services we provide (“Company Data”).
If you choose to apply for a job through our Site – we may request information about your education, other qualifications, and employment preferences.
If you attempt to make a purchase – we may request payment information.
You may elect not to provide us with all of the information we request. However, in that event, certain features of our Site may not be available or fully functional.
2.2. INFORMATION COLLECTED FROM OTHER SOURCES
We also obtain Personal Data in order to gain a better understanding of user needs and interests. The type of information we gather from other sources includes: (1) background information regarding your affiliation, title, and employer from public sources such as your Facebook, Google Plus, Pinterest, LinkedIn, and Twitter accounts; and (2) websites that you visit via cookies.
A cookie is a small text document which often includes an anonymous unique identifier. When you visit a website, that website’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites.
There are two types of cookies: (1) first-party cookies and (2) third-party cookies. First-party cookies are created by the website you visited; the website is shown in the address bar. Third-party cookies are created by other websites; these websites own some of the content, like videos or images, that you see on the webpage you visit. The first-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your Personal Data. The third-party cookies used on our Site are used mainly for understanding how the Site performs and how you interact with our Site, keeping our services secure, providing advertisements that are relevant to you, providing you with a better and improved user experience, and helping speed up your future interactions with our Site.
What types of cookies do we use?
Statistics: These cookies store information like the number of visitors to the Site, the number of unique visitors, which pages of the Site have been visited, the source of the visit, etc. These data help us understand and analyze how well the Site performs and where it needs improvement.
Functional: These are the cookies that help certain non-essential functionalities on our Site. These functionalities include embedding content like videos or sharing content on the Site on social media platforms.
Other organizations, such as ad networks, may be permitted to place cookies or similar technologies through our Site, and they may collect identifiable information about your online activities over time or across different websites.
Residents of the European Union – Will only be tracked via cookies if they have explicitly consented to such tracking.
Controlling Cookie Preferences – At this time, our Site does respond to browser “do-not-track signals,” which may be emitted by your browser to request that websites refrain from placing cookies and similar technologies. You can use your browser settings to block some or all cookies, but doing so may impair the functionality of our Site.
IP Addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data, known as “traffic data,” so that data (such as the web pages you request) can be sent to you.
2.3. HOW WE USE YOUR PERSONAL DATA
We use your Personal Data to:
- Provide you the materials you have requested;
- Suggest other materials or offer services that might interest you;
- Enable our staff to contact you regarding products or services that fit your needs;
- Communicate with you, such as to address feedback you may provide or to advise you of our services, promotions, and pricing;
Process purchases you make;
- Allow you to use interactive Site features, such as commenting on blog posts;
- Operate, analyze and improve our Site, including modifying or adding features and developing content and communication strategies;
- Administer or improve our business and our services, the applications and other processes we use to deliver those services, and the promotional materials we have developed to describe those services;
- Perform research and analyses;
- Protect the integrity of our Site, information systems, and security;
- Prevent physical harm or financial loss; and
- Engage in certain administrative purposes, such as risk management, fulfilling legal obligations, addressing compliance needs, and resolving or defending legal claims.
2.4. WHO WE SHARE YOUR PERSONAL DATA WITH
ROI does not sell your Personal Data to any third parties. We may share your Personal Data in the following ways:
- Third-party vendors – that assists us with our mailing; this data sharing enables us to mail information to you.
- Co-Sponsors – when participating in Co-Sponsored initiatives (e.g. online and in-person events, whitepaper downloads), data collected from form submission may be shared with Co-Sponsors. When shared, this data is governed by each individual Co-Sponsor’s Policy and may be used by the Co-Sponsor for follow-up purposes. If an initiative is co-sponsored and data collected will be shared, the submission page will provide this notice.
- Change of control – in certain cases, such as bankruptcy, merger, acquisition, sale, or change of control, your data may be transferred to a third party.
- Law Enforcement/Court orders – we may disclose information when legally compelled to do so; in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights, which may include to law enforcement or other legal authorities.
- Data Analytics – we may share your data with other companies or individuals that contract to provide services, such as data analytics or website optimization, in order to enable them to perform those services.
2.5. HOW LONG YOUR PERSONAL DATA WILL BE KEPT
Unless otherwise required by law or regulation or you request deletion, your Personal Data will be kept for a period of three years from the last date of Site or email activity. ROI has determined that three years of data enables us to stay connected with users who are most likely to use our services.
2.6. REASONS WE CAN COLLECT AND USE YOUR PERSONAL DATA
To process your Personal Data, we typically rely upon your consent, contract performance, our legitimate business interest, or compliance with law. By using this Site (and where required providing other forms of consent), you agree to our use of your Personal Data as outlined in this Policy.
3. Keeping Your Personal Data Secure
The Internet is not a secure medium. Nevertheless, we maintain appropriate administrative, physical, and technical safeguards intended to protect identifying information we collect when you use our Site, such as secure sockets layer encryption technology on all pages of the Site, restricted access of data, and employee training.
4. General User Rights
You have a number of important rights free of charge. In summary, they include rights to:
Fair processing of information and transparency over how we use your use Personal Data;
- Access to your Personal Data and to certain other supplementary information that this Policy is already designed to address;
- Request disclosure of information collected;
- Request disclosure of information sold;
- Require us to correct any mistakes in your information which we hold;
- Require the erasure of Personal Data concerning you;
- Receive the Personal Data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to a third party in certain situations;
- Object at any time to processing of Personal Data concerning you for direct marketing;
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
- Object in certain other situations to our continued processing of your Personal Data;
- Otherwise restrict our processing of your Personal Data in certain circumstances;
- Nondiscrimination relating to Consumers who exercise these rights; and
- Opt-out at the following link: http://www.bonnemamie.com/connect/do-not-sell-my-personal-info/.
If you would like to exercise these rights, please contact us as described below.
5. Rights of Certain Types of Users
Subject to local law, you may have certain rights with regard to your Personal Data. To learn more about the Personal Data we collect about you or the rights you may have, please contact us at the contact information below. These rights may include the following rights to: (1) access or rectify your Personal Data or request its deletion, (2) request a restriction on the processing of your Personal Data, (3) object to the processing of your Personal Data, or (4) exercise other rights with respect to your Personal Data. If you would like to exercise these rights, please contact us as described below. While we strongly encourage you to first raise any questions or concerns about your Personal Data directly with us, you may have a right to lodge a complaint with the relevant supervisory authority.
Regarding international Users – the Site is hosted in the United States and is intended for Users in the United States. If you are a consumer accessing the Site or using the Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use and disclosure that differ from U.S. laws, your continued use of the Site, which is governed by U.S. law and these terms, indicates your consent to transfer of your Personal Data to the United States.
5.1 INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA/EUROPEAN UNION (EU) – GDPR
ROI Revolution’s headquarters and offices are in the United States and we do not intentionally target European visitors to our Site. For clients in the European Union (“EU”), where data collections specifically apply to them, ROI Revolution complies with the EU General Data Protection Regulation 2016/679/EU (“GDPR”) as set forth by the EU regarding the collection, use, and retention of Personal Data from the EU member countries and Switzerland.
If you are a European resident or considered a Data Subject under GDPR, you have the following rights:
- Right to withdraw consent to the Processing of Personal Data at any time;
- Right to object to the Processing of Personal Data if the Processing is carried out on a legal basis other than consent;
- Right to learn if Personal Data is being Processed by ROI Revolution, obtain disclosure regarding certain aspects of Processing, and obtain a copy of the Personal Data undergoing processing (ROI Revolution reserves the right to charge you a small but reasonable fee for this service, if requests are unfounded, repetitive, or excessive);
- Right to verify the accuracy of Personal Data and ask for it to be updated or corrected;
- Right, under certain circumstances to restrict the Processing of Personal Data (in this case, ROI Revolution will not Process Personal Data for any purpose other than storing it);
- Right to receive Personal Data in a structured, commonly used, machine-readable format and, if technically feasible, to have it transmitted to another Controller without any hindrance (this provision is applicable provided that the Personal Data is processed by automated means and that the processing is based on your consent, on a contract which you are a part of or on pre-contractual obligations thereof); and
- Right to bring a claim before your competent data protection authority (DTA).
5.2 CALIFORNIA PRIVACY RIGHTS (CCPA)
We abide by California law where applicable for any California residents using our Site. You can request access to and/or revision of certain Personal Data by contacting us as described below. If you wish to limit the emails you receive from us, you can let us know by contacting us. California residents can make certain requests about their Personal Data under the California Consumer Privacy Act (“CCPA”). Specifically, if you are a California resident, you may request that we:
- Provide you with information about the categories of Personal Data we collect, disclose or sell about you, the categories of sources of such information, the business or commercial purpose for collecting or selling your Personal Data, and the categories of third parties with whom we share Personal Data (such information is also set forth in this Policy);
- Provide access to and/or a copy of certain information we hold about you;
- Delete certain information we have about you; and/or
- Provide you with information about the financial incentives that we offer to you, if any.
Verifying Your Request
Only you, or a person that you authorize to act on your behalf, may make a request related to your Personal Data. In the case of access and deletion, your request must be verifiable before we can fulfill such request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected Personal Data or a person authorized to act on your behalf (e.g., previous transactions of person to whom request relates).
We will only use the Personal Data that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority. The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. If you are a California resident and would like to exercise any of your legal rights under the CCPA, please contact us as described below.
“Do Not Sell My Personal Information” Rights
If you are a California resident, California Civil Code Section 1798.120 may permit you to “opt out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in the CCPA). This Policy describes the limited circumstances in which we may share your information with third parties and the procedures for opting out of such disclosures.
ROI Revolution also operates consistently with Canadian Anti-Spam Legislation (“CASL”). We do not send unauthorized Commercial Electronic Messages (“CEM”) to Canadian email addresses, unless they have opted-in to receive CEM. We understand a message sent to request consent is also considered CEM under CASL and we do not engage in this activity.
5.4 CHILDREN’S POLICY
ROI Revolution’s Site is not intended for children under 16 years of age, nor do we knowingly market or sell any goods or services to persons under the age of 18. Accordingly, we do not knowingly process Personal Data from anyone under 18 years of age and anyone under 18 years of age should not submit any Personal Data to ROI Revolution.
6. Other Communications and Rights
Telephone – ROI Revolution seeks your consent before contacting you. Specifically, by entering your information and clicking to confirm submission, you are authorizing ROI Revolution and/or its service providers to contact you at the number you listed via phone or text (SMS), including (as necessary) using automated dialing technology, for marketing or advertising purposes, or regarding your business with us. No purchase is required. No agreement or signature is required for you to receive the services. Separate message and data rates may apply. To opt-out at any time, you may reply STOP to any ROI Revolution text message. We acknowledge that this consent may be revoked at any time, but that until such consent is revoked, you may receive calls and text (SMS) messages from ROI Revolution. If you are a job applicant, additional information will be collected, including sensitive Personal Data, and advanced consent will be obtained.
Email/Fax – ROI Revolution seeks your consent before contacting you. Specifically, by providing your contact information and clicking to confirm submission, you are authorizing ROI Revolution and/or its service providers to contact you via email or fax. We may collect and send you email for the following purposes, but will always accurately identify ourselves and use truthful and accurate subjects and information.
- Send general information and answer questions and queries.
- Provide sales updates and information.
- Engage in marketing activities.
- Determine collaboration or partnership interest/opportunities of mutual interest.
We have provided an “Unsubscribe” link at the bottom of any such email or communication and will promptly fulfill your request to opt-out/unsubscribe to these communications.
7. How to Contact Us
If you have any questions about our Policy or would like to exercise any of the rights described above, please contact us through one of the following channels:
- Email: Privacy@roirevolution.com
- Address: Operations Manager, ROI Revolution, Inc., 4401 Atlantic Avenue, Raleigh, NC 27604 USA
- Telephone: 919-954-5955; please ask for the Operations Manager
Note: If you would like this notice in another format (for example: audio, large print, braille), please contact us (see “How to Contact Us” above).