This Privacy Policy describes the policies and procedures of RippleMatch Inc. (“we”, “our” or “us”) on the
collection, use and disclosure of your information on https://www.ripplematch.com/ (the “Site”) and the
services, features, content or applications we offer on the Site or through our owned and operated social media
accounts (collectively with the Site, the “Services”). We receive information about you from various sources,
including: (i) if you register for the Site and the Services, through your user account on the Services (your
“Account”); (ii) your use of the Services generally; and (iii) from third party websites and services. When you
use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other
uses of your information as described in this Privacy Policy.
For the purposes of the EU General Data Protection Regulation
2016 (the “GDPR”), RippleMatch Inc. is the data controller and is responsible for your Personal Information.
What Does This Privacy Policy Cover?
This Privacy Policy covers the treatment of personally identifiable
information (“Personal Information”) gathered when you are using or accessing the Services. This Privacy Policy
also covers our treatment of any Personal
Information that our business partners share with us or that we share with our business partners.
The term “Personal Information” as used in this Privacy Policy includes any information that enables
us to identify you, directly or indirectly, by reference to an identifier such as your name, identification
number, location data, online identifier or one or more factors specific to you.
This Privacy Policy does not apply to the practices of
third parties that we do not own or control, including but not limited to any third party employers, websites,
services and applications (“Third Party Services”) that you elect to access through the Service or to
individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party
Services that
share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those
Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you
access.
What information Do We Collect
The information we gather enables us to personalize, improve and continue to operate the Services. In connection
with certain aspects of the Services, we may request, collect and/or display some of your Personal Information.
We collect the following types of information from our users.
Account Information:
If you create an Account, you will provide information that could be Personal Information, such as your name,
educational background, work history, and interests, as well as a username, password and email address. You
acknowledge that this information may be personal to you, and by creating an account on the Services and
providing Personal Information to us, you allow others, including us, to identify you and therefore may not be
anonymous.
We may use your contact information to send you information about our Services, but only when we feel such
information is important, and where you have given your consent if required under applicable law. You may
unsubscribe from these messages through your Account settings, although we, regardless, reserve the right to
contact you when we believe it is necessary, such as for account recovery purposes.
User Content:
Some features of the Services may allow you to provide content to the Services, such as a detailed educational
and work profile and a resume. All content submitted by you to the Services may be retained by us indefinitely,
even after you terminate your account.
If you are a European resident, we will store your Personal Information in a form that permits us to identify
you for no longer than is necessary for the purpose for which the Personal Information is processed. We store
your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our
agreements and rights, or if it is not technically and reasonably feasible to remove it. Otherwise, we will seek
to delete your Personal Information within a reasonable timeframe upon request.
We may continue to disclose such content to third parties in a manner that does not reveal Personal Information,
as described in this Privacy Policy.
IP Address Information and Other Information Collected Automatically:
We may automatically receive and record information from your web browser when you interact with the
Services, including your IP address and cookie information. This information is used for fighting
spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g.,
what links you have clicked on).
Generally, the Services automatically collect usage information, such as the number and frequency of
visitors
to
the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner
that
would identify you personally. This type of aggregate data enables us and third parties authorized by us to
figure out how often individuals use parts of the Services so that we can analyze and improve them.
We may collect some device-specific information if you access the Services using a mobile device. Device
information may include but is not limited to unique device identifiers, network information, and hardware
model, as well as information about how the device interacts with our Services.
We may combine this information with information you give to us and information we collect about you. We
will
use this information and the combined Personal Information for purposes set out in this Privacy Policy
(depending on the types of information we receive).
Email Communications:
We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer
service.
Information Collected Using Cookies:
Cookies are pieces of text that may be provided to your computer through your web browser when you access
awebsite. Your browser stores cookies in a manner associated with each website you visit. We use cookies to
enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise
use the Services through the Internet. The cookies we use on the Site are as follows:
Session cookies: These temporary cookies expire and are automatically erased whenever you close your
browser window. We use session cookies to grant our users access to content and to enable actions they
must be
logged in to do.
Persistent cookies: These usually have an expiration date in the distant future and remain in your
browser
until they expire or you manually delete them. We use persistent cookies to better understand usage
patterns
so we can improve the site for our customers. For example, we may use a persistent cookie to associate
you
with your Account or to remember your choices on the Site.
Third party cookies: We permit limited third parties to place cookies through the Site to provide us
with
better insights into the use of the Site or user demographics or to provide relevant advertising to you.
These
third parties may collect information about a consumer’s online activities over time and across
different
websites when he or she uses our Site. For example, we utilize Google Analytics to analyze usage
patterns
of
the Site. Google Analytics generates a cookie to capture information about your use of the Site which
Google
uses to compile reports on website activity for us and to provide other related services. Google may use
a
portion of your IP address to identify their cookie, but this will not be associated with any other data
held
by Google.
Our cookies do not, by themselves, contain Personal Information, and we do not combine the general
information
collected through cookies with other Personal Information to tell us who you are. As noted, however, we do
use
cookies to identify that your web browser has accessed aspects of the Services and may associate that
information with your Account if you have one.
Most browsers have an option for turning off the cookie feature, which will prevent your browser from
accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to
decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies
active, because they enable you to take advantage the most attractive features of the Services.
We may also permit third parties to place cookies through the Site, as indicated above, to perform analytic
or
marketing functions. We do not control the use of such third party cookies or the resulting information and
we
are not responsible for any actions or policies of such third parties.
Information Related to Advertising and the Use of Web Beacons:
To support and enhance the Services, we may serve advertisements, and also allow third parties advertisements
through the Services. These advertisements are sometimes targeted and served to particular users and may come
from
third party companies called “ad networks.” Ad networks include third party ad servers, ad agencies, ad
technology
vendors and research firms. We may also use analytics service providers to analyze how you interact and engage
with our Services and our advertisements, so we can learn and make enhancements to offer you a better
experience.
Some of these entities may use cookies, web beacons and other technologies to collect information about your use
of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages,
links clicked and conversion information. This
information may be used by us and others to, among other things, analyze and track data, determine the
popularity
of certain content, deliver advertising and content targeted to your interests on our Services and other
websites
and better understand your online activity.
Advertisements served through the Services may be targeted to users who fit a certain general profile category
and
may be based on anonymized information inferred from information provided to us by a user, including Personal
Information (e.g., gender or age), may be based on the Services usage patterns of particular users, or may be
based on your activity on Third Party Services. We do not provide Personal Information to any ad networks for
use
outside of the Services.
To increase the effectiveness of ad delivery, we or our service providers may deliver a file (known as a “web
beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized,
aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to
serve targeted advertisements to you when you visit other websites. Because your web browser must request these
advertisements and web beacons from the ad network’s servers, these companies can view, edit or set their own
cookies, just as if you had requested a web page from their site.
Through the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”), several media and
marketing associations have developed an industry self-regulatory program to give consumers a better
understanding
of and greater control over ads that are customized based on their online behavior across different websites.
To
make choices about interest-based ads from participating third parties, please visit the DAA’s or NAI’s
consumer
opt out pages, which are located at
http://www.networkadvertising.org/choices/
or
www.aboutads.info/choices.
Information Related to Advertising Directed at European Residents
If you are based in the EU, we will only share your Personal Information
with
unaffiliated third parties for direct marketing purposes, or send you direct marketing communications related to
our own or third party products and services, if you have given your consent to receiving that marketing.
We will generally ask for your consent in line with the applicable law when
you first provide your Personal Information. You can choose to stop receiving direct marketing communications
from us at any time simply by following the “Unsubscribe” or “Manage Email Preferences” link at the bottom of
any promotional email, or by changing your Account settings.
Aggregate Information:
We collect statistical information about how both unregistered and
registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived
from
Personal Information. This statistical information is not Personal Information and cannot be tied back to you,
your
Account or your web browser.
How, and With Whom, Is My Information Shared?
The Services are designed to help you share information with others. As a
result, some of the information generated through the Services is shared publicly or with third parties.
Information You Elect to Share:
The Personal Information you provide to us is used to match you with
appropriate potential employers. As a result, the Personal Information you provide is entered into a database
that is searchable by employers who have decided to use our Services. In the event that an employer determines
it
wishes to contact you, that employer can use the Personal Information you provided to us to contact you
directly.
As mentioned above, this privacy policy does not apply to employers or
other Third Party Services, and we do not control how Third Party Services use or disclose your Personal
Information.
Individuals reading such information may use or disclose it to other individuals or entities without our control
and without your knowledge, and search engines may index that information. Because of this, despite commercially
reasonable efforts, we cannot guarantee the privacy of Personal Information submitted by you. Also note that if
you exchange messages with a potential employer to whom you were introduced through us, such employer may retain
the message history after you terminate communications and/or close your Account on the Services. We therefore
urge you to think carefully about including any specific information you may deem private before you submit it
through the Services or in correspondence with Third Party Services. We are not responsible for the privacy
policies and/or practices of Third Party Services, and you are responsible for reading and understanding those
Third Party Services’ privacy policies. This Privacy Policy only governs information collected on the Services.
IP Address Information:
While we collect and store IP address information, that information is not
made public. We do at times, however, share this information with our partners, service providers and other
persons with whom we conduct business, and as otherwise specified in this Privacy Policy.
Aggregate Information:
We share Aggregate Information with our partners, service providers and
other persons with whom we conduct business. We share this type of statistical data so that our partners can
understand how and how often people use our Services and their services or websites, which facilitates improving
both their
services and how our Services interface with them. In addition, these third parties may share with us
non-private, aggregated or otherwise non Personal Information about you that they have independently developed
or acquired.
Email Communications with Us:
As part of the Services, you may occasionally receive email and other communications from us, such as
communications relating to your Account. Communications relating to your Account will only be sent for purposes
important to the Services, such as password recovery.
User Profile Information:
User profile information including your username and other information you
enter may be displayed to other users to facilitate user interaction within the Services.
Information Shared with Our Agents:
We employ and contract with people and other entities that perform certain
tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with
our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not
have
any right to use Personal Information or other information we share with them beyond what is necessary to assist
us. You hereby consent to our sharing of Personal Information with our Agents.
Information Disclosed Pursuant to Business Transfers:
In some cases, we may choose to buy or sell assets. In these types of
transactions, user information is typically one of the transferred business assets. Moreover, if we, or
substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user
information would be one of the assets that is transferred or acquired by a third party. You acknowledge that
such transfers
may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth
in this policy.
Information Disclosed for Our Protection and the Protection of Others:
We also reserve the right to access, read, preserve, and disclose any
information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process
or governmental request, (ii) enforce this Privacy Policy and our Terms of Service, including investigation of
potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues,
(iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public.
This
includes exchanging information with other companies and organizations for fraud protection and spam/malware
prevention.
Information We Share With Your Consent:
Except as set forth above, you will be notified when your Personal
Information may be shared with third parties, and will be able to prevent the sharing of this information.
Security of Shared Personal Information
We require all third parties to respect the security of your Personal
Information and to treat it in accordance with the law. We do not allow our Agents to use your Personal
Information for their own purposes and only permit them to process your Personal Information for specified
purposes and in accordance with our instructions.
Where third parties are processing Personal Information on our behalf, they will be required to agree, by
contract or otherwise, to process Personal Information in accordance with applicable law. This contract will
stipulate,
among other things, that the third party and its representative shall act only on our instructions, or as
permitted by law.
Is Information About Me Secure?
Your Account information will be protected by a password for your privacy
and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and
protecting your password appropriately and limiting access to your computer and browser by signing off after you
have finished accessing your Account.
We seek to protect Account information to ensure that it is kept private;
however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or
software failure, and other factors, may compromise the security of user information at any time.
We otherwise store all of our information, including your IP address
information, using industry-standard techniques. We do not guarantee or warrant that such techniques will
prevent unauthorized access to information about you that we store, Personal Information or otherwise.
What Information of Mine Can I Access?
If you are a registered user, you can access information associated with
your Account by logging into the Services. Registered and unregistered users can access and delete cookies
through
their web browser settings.
Californian Privacy Rights
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice
identifying the categories of personal customer information which we share with our affiliates and/or third
parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If
you are a California resident and would like a copy of this notice, please submit a written request to the
following address: RippleMatch Inc., 5 West 19th Street, 6th Floor, New York, New York 10011 or info@ripplematch.com
European Residents
If you are based in the EU, we will only process your Personal Information for a purpose described in this
Privacy
Policy if:
you have provided your consent (which can be withdrawn at any time);
the processing is necessary for the performance of a contract we are about to enter into or have entered
into with you;
we are required by law to undertake such processing; or
the processing is necessary for the purposes of our legitimate commercial interests (except where such
interests are overridden by your rights and interests).
If you are based in the EU, in certain circumstances you have rights under data protection laws in relation to
your Personal Information that we hold about you—specifically to:
Request access to your Personal Information. You may have the right to request access to any Personal
Information we hold about you as well as related information, including the purposes for processing the
Personal Information, the recipients or categories of recipients with whom the Personal Information has been
shared, where possible, the period for which the Personal Information will be stored, the source of Personal
Information, and the existence of any automated decision making.
Request correction of your Personal Information. You may have the right to obtain without undue delay the
rectification of any inaccurate Personal Information we hold about you.
Request erasure of your Personal Information. You may have the right to request that Personal Information
held about you be deleted.
Request restriction of processing your Personal Information. You may have the right to prevent or restrict
processing of your Personal Information.
Request transfer of your Personal Information. You may have the right to request transfer of your Personal
Information directly to a third party where this is technically feasible.
Also, where you believe that we have not complied with our obligations under this Privacy Policy or European
data protection law, you have the right to make a complaint to an EU Data Protection Authority. You can
exercise
any of these rights by emailing us at info@ripplematch.com.
How Can I Delete My Account?
Should you ever decide to delete your Account, you may do so by emailing info@ripplematch.com. If you terminate your Account, any association
between your Account and information we store will no longer be accessible through your Account. However,
given
the nature of sharing on the Services, any public activity on your Account prior to deletion will remain
stored
on our servers and will remain accessible to the public, subject to applicable law.
What Choices Do I Have Regarding My Information?
You can use many of the features of the Services without registering, thereby limiting the type of
information that we collect.
You can always opt not to disclose certain information to us, even though it may be needed to take
advantage of some of our features.
You can delete your Account. Please note that we will need to verify that you have the authority to delete
the Account, and activity generated prior to deletion will remain stored by us and may be publicly
accessible,
subject to applicable law.
What Happens When There Are Changes to this Privacy Policy?
We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy
Policy in effect at the time such information is used. If we make changes in the way we collect or use
information, we will notify you by posting an announcement on the Services or sending you an email. A user is
bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first
posted.
International Transfers
We are headquartered in the United States. Please be advised that your information will be accessed
by us or transferred to us in the United States or to our affiliates, partners, or service providers
who are located worldwide. If you are visiting our Site from outside the United States, be aware
that your information will be transferred to, stored, and processed in the United States where
our servers are located, and our central database is operated and where laws regarding processing
of Personal Information may be less stringent than the laws in your country. If you have concerns
about our processing of your Personal Information, please do not use the Services.
Where Personal Information is transferred from the EU to a third party located in a country that
has not received an adequacy decision by the European Commission, we rely on appropriate safeguards.
We will execute appropriate Data Processing Agreements with the latest European Commission approved
Standard Contractual Clauses for transfer of data between a Controller (you) and Processor (us).
What If I Have Questions or Concerns?
If you have any questions or concerns regarding privacy using the Services, or if you wish to exercise any of
the rights relevant to you listed above, please send us a detailed message to
info@ripplematch.com or RippleMatch
Inc., 5 West 19th Street, 6th Floor, New York, New York 10011. We will make every effort to resolve your concerns.
