Privacy Notice

‍1. What is Personal Information?

We collect two types of information from you: Personal Information (also referred to as “Personal Data” under applicable laws) and non-Personal Information. 

Personal Information means any information which may potentially allow your identification with reasonable means (for example, email address or name). 

Non-Personal Information, by contrast, can be defined as any information that does not relate to an identified or identifiable natural person. This may include, for example, your aggregated usage information and technical information transmitted by your device (e.g. the device you use, the type of browser and operating system your device uses, language preference, access time, etc.). Our use of non-Personal Information is outside the scope of this Privacy Notice. 

If we associate Non-Personal Information with Personal Information, we will treat such information as Personal Information as long as such association exists.

2. What types of Personal Information we collect?

We may collect and process the following types of Personal Information:

• Account information. If you choose to register an account with our Services, we may collect your full name, username, email address and phone number. We collect this information to create, maintain and secure your account. If you choose to register an account, you are responsible for keeping your account credentials safe. 
• Communication information. When you communicate with us, for example  through the "Contact Us" option on our Website or otherwise provide us with any feedback, we collect your full name, email address, phone number, the contents of those communications, and/or attachments you may send us, and/or answers to surveys or questionnaires that you may submit, and any other information you choose to provide us. 
• Device and technical information. We may collect technical information about your interaction with our Services. This information includes Internet protocol (IP) address, unique identifiers and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, device type, operating system, internet service provider and other information about actions taken through the use of our Services. We may also collect information through session recording, such as page content, click/touch, movement, scroll, keystroke activity, screenshots, window titles, browsing history, log files, user activity, time stamps, alerts, and similar information.
• Information you provide directly to us. We may process additional Personal Information if you choose to provide us with it directly, for example, during your communication with us or other engagement with our services (i.e. our blog, social media etc.).
• Information from other sources. We may also obtain information (that in general will not contain Personal Information) about you from other sources, including private and publicly – or commercially – available information, and through third-party partners and service providers.

3. Why do we process your Personal Information?

This section explains for what purposes we use your Personal Information and, where applicable, outlines the legal bases that underlie our usage. 

Where applicable, the following describes the specific purposes for which you have voluntarily provided your Personal Data and in respect of which you have not indicated an objection to, or withdrawal of consent for, our use of such Personal Information, as recognized under applicable law. Where you wish to indicate such objection or otherwise withdraw your consent to such use, please refer to Section 5 ("Your rights") for information on how you may exercise this right at any time. 

4. With whom do we share your Personal Information

We may disclose your Personal Information as described below:

5. Your rights

Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your Personal Information. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask us to exercise the following rights:

1. Rights of access: The right to receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with supplementary information.
2. Right of rectification: The right to request rectification of your Personal Information that is in our control, in the event that you believe the Personal Information held by us is inaccurate, incomplete or outdated.
3. Right of deletion/erasure: The right to request that we erase or delete Personal Information held about you.
4. Right to restrict processing: The right to request to restrict the processing of your Personal Information by us.
5. Right of portability: The right to receive the Personal Information you provided us with in a structured, commonly used and machine-readable format, and the right to transmit those data to another controller.
6. Right to object to processing: The right to request that we cease to conduct certain Personal Information processes at any time.
7. Right to withdraw your consent: Where we rely on consent to process Personal Information about you, you have the right to withdraw your consent to the collection, use or processing of your Personal Information at any time. Exercising this right will not affect the lawfulness of processing your Personal Information based on your consent before its withdrawal.
8. Right to limit use and disclosure of your sensitive Personal Information: The right to request to limit the use and disclosure of your sensitive Personal Information, to that use which is necessary to perform our Services.
9. Right not to be subject to automated decision making: The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significant effects.
10. Right to opt-out of the sale or share of Personal Information: The right to opt-out of the "Sale" or "Share" of Personal Information (as these terms are defined under applicable laws) for behavioral advertising purposes. 
11. Right to non-discrimination: You have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.

Exercising your rights:

1. You may request to exercise these rights by contacting us at: support@ryft.io. We will handle these requests, complaints or queries in accordance with applicable laws, and provide you with a reply in a timely manner. Please note that we may require additional information and documents when processing your request, including certain Personal Information, in order to authenticate and validate your or any applicable authorized agent’s identity and to process your request. Such additional information may also be retained for legal purposes in accordance with this Notice.
2. In some jurisdictions, you have the right to appeal a rejection of your request. Please submit your appeal to support@ryft.io. If your appeal is denied, certain jurisdictions allow you to submit a complaint via the local attorney general or another competent authority responsible for handling such matters.
3. If you think we have infringed data protection laws, you can file a claim with the data protection supervisory authority in your jurisdiction of residency, as applicable to you.

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

6. Additional information for US residents 

This Section addresses specific disclosure requirements under the applicable laws pertaining to data privacy, data security, and the protection of Personal Information in the United States (collectively, "US Privacy Laws").

6.1. Collection of Personal Information

In the preceding twelve (12) months, we have collected, the following categories of Personal Information:

6.2. Sources of Personal Information

In the preceding twelve (12) months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

1. Directly, through your activity on our Services: For example, from your interaction with the Website, our Services and when you provide information via our Services;
2. Indirectly from you: We track some activities across the internet, for example, when you view or interact with certain content, web pages or ads.
3. From third parties: For example, from service providers who assist us in performing the Services.

We do not offer financial incentive to end users for providing Personal Information.

6.3. Disclosure of Personal Information 

We do not “Sell” or “Share” your Personal Information, as these terms are defined under US Privacy Laws. However, we disclose Personal Information about you.

In the preceding twelve (12) months, we may have disclosed your Personal Information as follows:‍

When we disclose Personal Information, we ensure that the recipient only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the Personal Information they receive, and to use it for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations.

6.4. Purposes for collection, processing and sharing

In addition to the practices detailed in this Notice, we also use and disclose the Personal Information we collect for the following commercial and business purposes:

1. Auditing related to our interactions with you;
2. Legal compliance;
3. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and necessary prosecution;
4. Debugging;
5. Performing services (for us or our partners);
6. Internal research for technological improvement;
7. Internal operations;
8. Activities to maintain and improve our services; and
9. Other one-time or short-term uses.

6.5. Authorized agent

If you are a California resident, you may only designate an authorized agent to make a request on your behalf if: (i) The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and (ii) you sign a written declaration that you authorize the authorized agent to act on your behalf. The request must: (i) provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, and (ii) describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

6.7. Direct marketing requests

California Privacy Rights. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to support@ryft.io. Please note that we are only required to respond to one request per customer each year.

7. How do we protect your Personal Information?

We are SOC 2 Type 2 compliant and ISO-27001 certified. In addition, we have implemented administrative, technical and physical, safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. Your Personal Information is protected by robust safeguards to ensure secured processing. For example, we ensure Personal Information is encrypted both in transit and at rest, and any access is strictly limited to a minimum number of authorized individuals who are subject to confidentiality commitments. 

We will take all steps necessary to ensure that your Personal Information is treated securely and in accordance with this Notice, however, please note that the transmission of Personal Information via the internet is not completely secure. We cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

8. International transfer

Please note that we, as well as our service providers, may be located around the world. Any information that we collect, disclose or share, including (but not limited to) your Personal Information, may be stored and processed in various jurisdictions around the world for the purposes detailed in this Notice, including in countries that may not provide the same level of data protection as ‎the country where you reside. ‎ In such cases we will ensure that applicable safeguards and where required, legal mechanisms are used to ensure that the transfer is aligned with the applicable data protection laws.

9. Tracking technologies

When you visit or access our Services we use (and authorize 3^rd parties to use) pixels, cookies, web beacons and other similar technologies ("Tracking Technologies"). These Tracking Technologies allow us to automatically collect information about you, your device and your online behavior, to enhance your navigation in our Services, improve performance, perform analytics, and customize your experience.

What types of Tracking Technologies do we use?

We store first-party and third-party Tracking Technologies when you visit or access our Services. These Tracking Technologies may be stored for the duration of your visit on our Services or for repeat visits. 

The main types of Tracking Technologies we use can be categorized as follows:

• Strictly Necessary – These Tracking Technologies are automatically placed on your device when you access our Services. They are essential to enable you to log in, navigate, use the features of our Services, or to provide a service requested by you. We do not need to obtain your consent to use these Tracking Technologies. They may also be used for security and integrity purposes, such as detecting policy violations and enabling support or security features.
• Functionality – These Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, they are used for authentication (to remember when you are logged-in) and support other features of our Services.
• Performance and Analytics – These Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services). They are used for analytics, research and statistical purposes (based on aggregated information). Our Website and Services use analytics tools, including Google Analytics, a web analysis service provided by Google Inc. (“Google”) which is based on Tracking Technologies. The information generated by these Tracking Technologies is usually sent to and stored on Google server in the USA. On behalf of the Company, Google will use the generated information to evaluate your use of the Website and the Services, to compile reports on website activities, and to provide the website operator with additional services connected with website and internet use. The IP address transmitted by your browser in connection with Google Analytics is not collated with other data by Google.  We use the information we get from Google to maintain and improve our Website and Services. We do not combine the information collected through the use of Google with Personal Information we collect. Further information about the privacy practices of Google Analytics is available here. Further information about your option to opt-out of Google Analytics is available here. We may add or remove analytic tools at any time.
• Marketing and Advertising – These Tracking Technologies are used to deliver tailored offers and advertisements, based on your interests, and to perform email marketing campaigns. We may share this information with advertisers or use it to better understand your interests, for example, to show more relevant ads, enable to share pages with social networks, or allow you to post comments on our sites. 
• Social Media and Similar – These Tracking Technologies include social media features, such as third-party log-in services. They may be hosted by a third-party or directly on our Services. Your interactions with these features are governed by the privacy statement of the company providing them. 

How can you control Tracking Technologies?

Except for Strictly Necessary Tracking Technologies, you can always withdraw your consent to non-essential ones through your web browser or device settings, usually found in the ‘Options’ or ‘Preferences’ menu of your browser.

The following links may be helpful for information on how to manage your Tracking Technologies on some browsers: Google Chrome; Internet Explorer; Mozilla Firefox; Safari (Desktop); Safari (Mobile); Android Browser; Microsoft Edge; Opera; and Opera Mobile.

Any such changes may require you to manually adjust preferences each time you visit a site, and some services or functionalities may not work. If you reject Tracking Technologies through your browser, you may still use the Website and Services, but some features may be limited.

Do-Not-Track (DNT) Signals

Cal. Bus. And Prof. Code Section 22575 requires us to notify you about how we handle “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers, therefore, we do not respond to them. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.

Advertisers Tracking Technologies

If you are primarily concerned about third-party Tracking Technologies generated by advertisers, and you live in the USA, Canada or Europe, you can also opt out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance. Opt out from the collection of such data by visiting the following websites: www.aboutads.info/choices  (USA users); www.youradchoices.ca/choices (Canadian users); and www.yourchoicesonline.com (European users).

You can learn more and turn off certain third-party targeting and advertising Tracking Technologies by visiting the following third-party webpages: The Interactive Advertising Bureau (USA); The Interactive Advertising Bureau (EU); and European Interactive Digital Advertising Alliance (EU).

If you have enabled Global Privacy Control (“GPC”) (a technological tool that may be used to control your cookies and tracking preferences), you can manage your settings accordingly. To learn more about the GPC, please download and use a browser supporting the GPC browser signal by clicking here: https://globalprivacycontrol.org/. 

Additional information can also be found here: www.allaboutcookies.org and www.youronlinechoices.co.uk.

10. Social features

Certain features of the Services allow you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to access our pages on third-party platforms. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service. Since we don't own or control these third-party services, we are not responsible for their privacy practices, security measures, or content. We strongly recommend reviewing the terms of use and privacy policies of any third-party service you interact with.

11. Marketing

We may use Personal Information, such as your full name, email address, etc., collected by us or through our trusted third-party service providers for the purpose of providing users with promotional materials via different marketing techniques, such as, direct emails as well as products, services, websites and applications, which relate to: (i) other companies within our group, as applicable; or (ii) our business partners and affiliates, which we believe could interest you, subject to obtaining your explicit consent, when required by applicable law.

Users have the possibility at any time to decline receiving further marketing offers from us by either: following the links inserted in the promotional emails (e.g., selecting the opt-out link) or contacting our customer support. Please note that even if you unsubscribe from our marketing mailing list, we shall continue to send you Service-related updates and notifications.

You may opt-out of receiving our promotional or marketing emails (all or any part thereof) by clicking on the "unsubscribe" link in the emails that you receive from us or by contacting us at support@ryft.io.  

12. Minors

We do not knowingly collect Personal Information from Minors (as determined under the applicable laws where the individual resides; “Minor(s)”). By accessing or using our Services, you certify to us that you are not a Minor. In the event that we become aware 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 information from or about a Minor, please contact us at support@ryft.io. 

13. Data retention

We will retain your Personal Information for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. 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.

14. Updates to this Notice

We reserve the right to change this Notice at any time. The most current version will always be posted on our Website (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Notice. However, if this Notice is changed in a significant way, a notice will be posted on the home page of the Website 7 days before the changes take effect, unless the changes originate from any legal or regulatory requirement, in which case, the change shall enter into force in accordance with such requirement.

15. Contact us

If you have any questions, concerns or complaints, please contact us at: support@ryft.io.