Ryft Privacy Policy

Last Revised: May [], 2025

This policy sets forth how Ryft Data, Inc. and its affiliates ("we", "us", or "Ryft") collect and process Personal Information (as defined below) through our website located at https://www.ryft.io/ (the "Website"). Where Ryft is providing its customers with a license or access and use right to its data management and optimization software solution (the "Solution"), and we process your Personal Information on behalf of or at the direction of the customer, who may be your employer or principal, then Ryft shall be deemed the processor/service provider and the customer will be the controller/business, as such terms are defined under applicable privacy and data protection laws. In such situations the processing of your Personal Information will be covered by the customer’s own policies and agreement(s) with you, provided that our processing of your Personal Information may also be subject to any data processing addendum (DPA) between us and the customer, and in the event of a conflict between this policy and the DPA, the DPA shall prevail. IN ADDITION, NOTHING IN THIS PRIVACY POLICY IS MEANT TO LIMIT ANY OF YOUR STATUTORY RIGHTS UNDER APPLICABLE PRIVACY LAWS.

Information collected through the Website

We may collect personal information about you, an individual user of our Website (“you” or "user"), meaning any information relating to an identified or identifiable natural person, or otherwise qualifying as "personal data", "personal information" or “personally identifiable information” as such terms are defined under applicable privacy and data protection laws (“Personal Information“).

When you use the Website or otherwise communicate with us in connection with Ryft's products and services (other than where Ryft processes your Personal Information on a customer’s behalf, as stated above), Personal Information about you will be collected as follows:

For Website users

We collect Personal Information when you register and log in to the Website, such as your full name and personal or business email address.
We also collect Personal Information that you provide us with voluntarily, such as your email address or phone number, for instance when you communicate with us via the 'contact us' option on the Website, provide us with feedback, suggestions, complaints or bug reports or register for updates or mailing list. In those cases, we will use such Personal Information to contact you. Such information may also include Personal Information shared with Ryft by third parties based on your consent to be contacted for marketing purposes.
We may record your use sessions of the Website and collect Personal Information regarding your use and device, which may include IP address, log and usage data and exact device type and geolocation.

For prospective users, contacts and prospective employees

We collect Personal Information we obtain from publicly available sources (e.g., professional networking sites), third-party data providers, or business partners about individuals who have not directly used the Website or our Solution, products and services but may have been identified as potential customers, users or relevant contacts. Such information includes basic contact details such as name, business email address, phone number, job title and other professional relevant data.

For the avoidance of doubt, if we combine Personal Information with non-personal information, the combined information will be treated as Personal Information as long as it remains combined.

Legal Basis of Processing

Depending on the type of use as detailed below, Ryft processes Personal Information based on the following legal basis:

Processing is necessary for the performance of a contract to which the data subject (as such term is defined under applicable privacy laws) is party, or in order to take steps at the request of the data subject prior to entering into a contract,
Processing is necessary for our legitimate interests and those of third parties for the purposes identified below
Processing is necessary to comply with our legal obligations.
Consent (with regards to marketing communications).

Data Integrity and Purpose Limitation

We use the information in the manners described in this privacy policy. In addition to those purposes listed herein, the information we collect, which may include your Personal Information, may be used by us for the following purposes:

To set up your account to provide you with and authenticate your access to the Website.
To send you relevant notifications, which are based on different activities and features offered by the Website or in the Solution.
Subject to any applicable marketing consent requirement, to communicate with you and to keep you informed of our latest updates, and share information on the Solution and any of our other products and services
To perform research, personalization or to conduct analytics in order to improve and customize the Website’s use per your needs and interests.
To support and troubleshoot any issues with the Website and to respond to your queries.
To investigate and resolve disputes in connection with your use of the Website.
To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Website.
To investigate violations and enforce our policies (including our Website terms, this privacy policy and our Copyright Policy, as amended from time to time), and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request, or to comply with our contractual obligations.
To assist us with our business operations (e.g., verifying and processing transactions).
To establish or exercise our rights to respond to legal claims, and to enforce and establish our intellectual property or other legal rights.
To detect and prevent harm to the rights, property or safety of Ryft, our affiliates, our users, yourself or any third-party.
To generate anonymized metadata, including via research or analytics, and use such anonymized metadata to improve the Website, and develop and improve our products and services.

Information Sharing

We do not rent or sell any Personal Information. We may share Personal Information with the following recipients:

Our third-party vendors engaged in providing services in connection with the Solution or sending marketing communications (the latter, with your consent);
Our subsidiaries and affiliated companies;
Auditors or advisers of our business; and
Any potential lenders to, purchasers or investors in Ryft.

Cookies and Related Technologies

We use cookies and other technologies in our related services, including when access the Website. Cookies are small data files that are placed on users’ devices to monitor how users interact with websites and other online services. Cookies can be used to identify your IP address, browser type, domain name, and specific web pages through which you click. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Website quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests, and to compile statistical data on your use of our Website or other products or services.

Ryft and our service providers may use cookies because they:

are essential for us to provide our services to you;
allow us to identify you for repeat visits (such as storing your preferences for your next visit(s));
help us optimize, personalize and/or otherwise improve your experience and/or the performance of the Website and our service and marketing-related communications with you;
allow us to associate your activities with other Personal Information found in third party databases, including by association with your email or home address; and
enable advertising delivered to you to be more relevant.

You may remove the cookies by following the instructions of your device preferences; You can find more information about cookies at www.allaboutcookies.org; however, if you choose to disable cookies, some features of our services may not operate properly and your online experience may be limited.

‍International transfer

Since Ryft operates globally, it may be necessary to transfer data, including Personal Information, to other countries than the country in which the information was collected. In these instances, we will transfer your data in accordance with the provisions of the applicable privacy legislation meant to safeguard the processing of your Personal Information.

‍For how long we retain the information

We retain the information that we collect from our users for as long as it is necessary based on the purpose it was collected for and taking into account compliance with our legal obligations, resolving disputes, and enforcing our rights. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. We may keep records containing users' Personal Information, account opening documents, communications, and anything else as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Your privacy rights

Certain jurisdictions provide users with certain statutory rights to their Personal Information. Subject to exemptions provided by law, and with proper identification, you may have the right to take certain actions regarding your Personal Information such as:

Right to verify your Personal Information (to access, delete, change or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
Right to request that we erase Personal Information about you (subject to any other legal obligation that may require us to keep that information);
Right to object to the processing of your Personal Information where our lawful basis is legitimate interest or direct marketing;
Right to restrict us from processing Personal Information pertaining to you (for example, you may request that we will stop using or sharing your Personal Information with third-parties); and
Right to export Personal Information in a portable format.

If you wish to exercise any of these rights, contact us at: support@ryft.io. When handling your request, we will ask for additional information to confirm your identity (which may include Personal Information). However, please note that if you choose not to allow us to process your Personal Information, we may be prevented from providing our Services or access to our Website.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you are not satisfied with our response, or believe we are collecting or processing your Personal Information in a manner that does not comply with applicable privacy laws, you can file a complaint to the applicable data protection authority.

Children's Privacy

We do not knowingly collect or solicit Personal Information from minors, being anyone under the age of consent (as determined under the applicable laws where the individual resides; "Minors"). By accessing, using or interacting with the Website, you represent and certify to us that you are not a Minor. In the event we learn that we have collected Personal Information from a Minor without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any Personal Information from or about a Minor, please contact us using the contact details provided below.

Changes to this Policy

Ryft may revise this privacy policy from time to time at its sole discretion. We will post any policy changes on this page. You are encouraged to regularly review this policy page for updates. Each version of this privacy policy will be identified at the top of the page by its effective date next to the "Last Revised" heading.

Contacting us

If you have any questions about Ryft's privacy policy or concerns about the way we process your Personal Information, or if you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at: support@ryft.io.