1.         General

We know that your privacy is important to you, and we work hard to earn and keep your trust.  Retrove Inc. (“Company,” “we,” “us,” and “our”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”). The words “you” and “your” refer to you as a user of the Platform (defined below), either as a visitor, registered customer, or employee of a Company customer. 

This Policy describes:

·      The types of information we collect from you or that you may provide when you access and use Company services offered on the website and website application located at https://www.retrove.net, the Company’s Chrome extension and related services, and any websites and blogs directly owned by the Company where this Policy is linked (collectively, our “Platform”).

·      Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on the Platform or in emails and other electronic messages between you and the Platform, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.

This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Platform (for further information, see below, “Third-party Websites”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, then please do not use the Platform.  By using the Platform, you agree to the terms of this Policy.  This Policy may change from time to time (see below, “Changes to this Policy”).  Your continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2.         Platform Terms of Service

This Policy should be read in conjunction with our Terms of Service, into which this Policy is incorporated by reference.y is incorporated by reference.

3.         What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and disclose personal information about you in accordance with this Policy.  Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). In particular, the Platform may collect the following categories of Personal Information from users of the Platform:

Category	Examples	Collected
Identifiers.	First and last name, postal address, email address, telephone number, unique personal identifier, online identifier, Internet Protocol address, account name.	YES
Payment Information	Financial account, debit card, credit card number.	YES
Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES

 

We obtain the categories of Personal Information listed above from the following categories of sources:

·      Directly from you. For example, when you:

o   register yourself with the Platform;

o   make a payment for one of our subscriptions;

o   subscribe to one of our e-newsletters; or

o   communicate with us, such as request information or provide feedback.

·      Indirectly from you. For example, through information we collect from you in the course of providing our services to you.

·      Directly and indirectly from activity on the Platform. For example, from Platform usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” section below.

Free-Text Boxes. The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting the Company to request further information.  When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services. 

Username and Password; Other Sources. We may ask you to create a username and password that should only be known to you.  When you provide this information to us, you are no longer anonymous.  Moreover, we may receive information about you from other sources and add it to the information you have provided to us.

Information of Other Individuals.  You may have the opportunity to provide information of other individuals. When providing such information, you are solely responsible for obtaining the necessary consents and authorizations from any individuals in accordance with applicable data security laws and regulations, and the Company shall not be responsible or held liable for your failure to obtain the necessary consents.

Credit Card Information. Please note that for any credit card information provided on the Platform, we utilize a trusted third-party PCI-DSS compliant payment processor to process all of your transactions and it collects and maintains the necessary Personal Information needed to necessitate such transactions.

4.         Automated Information Collection

In addition to the information that you provide to us, we may also collect information about you during your visit to the Platform.  We collect this information using automated tools that are detailed below.  These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Platform.  Some of the tools we use to automatically collect information about you may include:

(a)  Cookies.  A “cookie” is a small data file transmitted from a website to your device’s hard drive.  Cookies are usually defined in one of two ways, and we may use either (or both) of them: 

(1)  session cookies, which do not stay on your device after you close your browser, and

(2)  persistent cookies, which remain on your device until you delete them or they expire. 

We may use the following categories of cookies on the Platform.

                                               i.     Strictly Necessary Cookies.  These cookies are essential in order to enable you to move around the Platform and use its features. Without these cookies, services you have requested cannot be provided.

 

                                             ii.     Performance Cookies.  These cookies collect anonymous information on how you use the Platform to help us understand how you arrive at the Platform, browse or use the Platform and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.

 

                                            iii.     Functionality Cookies.  These cookies remember choices you make such as the country from which you visit the Platform, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to the Platform more tailored to your preferences. The information in these cookies may be anonymized.  These cookies cannot track your browsing activity on other websites.

Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings.  However, by disabling cookies on your device, you may be prohibited from full use of the Platform’s features or lose access to some functionality.

(b)  Google Analytics.  The Platform sends aggregated non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Platform’s performance.  For more information on how Google Analytics supports the Platform and uses information sent from the Platform, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.

 

(c)  Web Beacons.  A Web Beacon is an electronic image.  Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior.  If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails.  We may also use them to track if you click on the links and at what time and date you do so.  Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on the Platform.  This information is only collected in aggregate form and will not be linked to your Personal Information.  Please note that any image file on a webpage can act as a Web Beacon.

 

(d)  Third-party Websites and Services.  We work with a number of service providers of marketing communications technology.  These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide.  The information collected can be gathered on the Platform and also on the websites where our marketing communications are appearing.  For example, we may collect data where our banner advertisements are displayed on third-party websites.

5.         How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• security, credit or fraud prevention purposes;
• providing you with effective customer service;
• providing you with a personalized experience when you use the Platform;
• contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• contacting you with information and notices related to your use of the Platform;
• inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
• better understanding your needs and interests;
• improving the content, functionality and usability of the Platform;
• improving our products and services;
• improving our marketing and promotional efforts; and

·      any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

Duration. The length of time Company intends to retain Personal Information, including sensitive personal information, if any, is for as long as reasonably necessary to carry out Company’s intended business purpose for such information. 

6.         How We Disclose Your Information

We do not sell or lease your Personal Information to any third party.  We may disclose your Personal Information to a third party for a business purpose, including the following categories of third parties:

• Third-party Service Providers. We may disclose Personal Information collected through the Platform with third-party Service Providers who act for or on behalf of the Company. These third parties may need information about you to perform their functions. “Service Providers” may include suppliers, companies and consultants that provide website hosting, software development, payment processing, website and data analytics, information technology and related infrastructure support, customer service, and email delivery.
• Your Employer.  If you are an employee of a company that has a subscription with us, we may disclose your information with your applicable employer, such as, but not limited to, when managing all active accounts under the employer’s subscription with us. The Company is not responsible or liable for any uses of your information or your content by your employer.
• In Aggregate or De-Identified Form. We may aggregate or otherwise anonymize the data we collect for purposes of analytics, research, marketing and other business interests of the Company.  Such use shall not include Personal Information or information that can identify you as an individual or reasonably be used to identify you.

Except as described in this Policy, we will not disclose your information with third parties without your notice and consent, unless it is under one of the following circumstances: 

·      Legal Reasons.

 

o   We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;

o   To respond to duly authorized information requests from law enforcement or other governmental authorities;

o   To enforce our agreements, policies, or the Terms of Service;

o   To investigate and prevent security threats, fraud, or other malicious activity; or

o   To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.

·      Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell, or reorganize its business in selected countries.  Under these circumstances, it may be necessary to disclose or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.

7.         Digital Millennium Copyright Act.

Notification.  We take claims of copyright infringement seriously. We will respond to notices of alleged copyright infringement that comply with applicable law. If you believe any materials accessible on or from the Services infringes your copyright, you may request removal of those materials (or access to them) from the Website by submitting written notification to our copyright agent (designated below).  In accordance with the Online Copyright Infringement Liability Limitation Act of the Digital Millennium Copyright Act (17 U.S.C. § 512) ("DMCA"), the written notice (the "DMCA Notice") must include substantially the following:

  (i) a physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed;

(ii) identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works on the service are covered by a single notification, a representative list of such works from the service;

(iii) identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit Company to locate the material;

(iv) information reasonably sufficient to permit the Company to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted;

(v) a statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law;

(vi) a statement that the information in the notification is accurate; and

(viii) under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.  If you fail to comply with all of the requirements of Section 512(c)(3) of the DMCA, your DMCA Notice may not be effective.  Upon removing any allegedly infringing material, the Company will notify the alleged infringer of such takedown.

Please note that under Section 512(f) of the DMCA, any person who knowingly materially misrepresents that material or activity is infringing may be subject to liability.

Counter Notification.  If you elect to send our copyright agent a counter notice, to be effective it must be a written communication that includes the following (please consult your legal counsel or See 17 U.S.C. Section 512(g)(3) to confirm these requirements):

(i) a physical or electronic signature;

(ii) identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access to it was disabled;

(iii) a statement under penalty of perjury that the subscriber has a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled;

(iv) adequate information by which we can contact you, including your name, address, and telephone number; and

(v) a statement that the subscriber consents to the jurisdiction of a federal district court for the judicial district in which the address is located, or if the subscriber's address is outside of the United States, for any judicial district in which the Company may be found, and that the subscriber will accept service of process from the person who provided notification under subsection (c)(1)(C) or an agent of such person.

The DMCA allows us to restore the removed content if the party filing the original DMCA Notice does not file a court action against you within ten (10) business days of receiving the copy of your counter notice.  Please note that under Section 512(f) of the DMCA, any person who knowingly materially misrepresents that material or activity was removed or disabled by mistake or misidentification may be subject to liability.

The Company’s designated copyright agent or authorized official to receive notifications and counter-notifications of claimed infringement is:

Thomas Puech, Retrove Inc., 222 W Merchandise Mart Plaza Suite 1212, Chicago, Illinois, 60654, email: thomas@retrove.net. 

A summary of the DMCA can be obtained from the U.S. Copyright Office.

8.         Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed.  Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

From time to time, we may send you email newsletters and marketing emails.  You may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email.  Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. Even if you opt-out of receiving marketing material, we may still need to contact you with important information about your account or responding to your requests or questions.  

9.         Text Messaging

You may have the opportunity to receive SMS or "text" messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties.  Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested.  In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number.  In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us.  You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following the instructions provided in our communications to you.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy. 

10.     Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately.  We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements.  We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security.  We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it. 

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

11.     Information of Minors

We do not intentionally seek to gather information from individuals under the age of thirteen (13).  We do not target the Platform to minors, and would not expect them to be engaging with the Platform or services.  We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet.  If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

12.     Feedback

We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, or ideas you provide to us (collectively, “Feedback”) will be treated as non-proprietary and non-confidential. Your Feedback on or through this Website may be available to others who visit this Website. In addition, we may use your Feedback in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Feedback for such purposes. Therefore, you should have no expectation of privacy with respect to your Feedback on or through this Website. You should not submit any content you do not wish to make available to the general public, and you must take special care to make sure your Feedback comply with our Terms of Service apply to Feedback on or through this Website. In particular, your Feedback must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Feedback. apply to Feedback on or through this Website. In particular, your Feedback must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Feedback.

13.     Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates.  The Platform may link to third-party websites and services. For example, if you click on an advertisement on the Platform, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them.  Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information. 

14.     Your Rights Under State Law

California

·      Shine the Light law.  Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.

·      Do Not Track Signals.  Other than as disclosed in this Disclosure, the Platform does not operate any differently when it receives Do Not Track signals from your internet web browser.

·      WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. We do not “sell” or “share” Personal Information, as those terms are defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020.

Your Consumer Rights

Some state laws in the United States provide consumers with additional rights with respect to their personal information (also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act.  Any personal information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. If you are a consumer in a state that provides consumer rights, please be advised that Company is not a “business” or “controller” as that term is defined under applicable state laws and therefore does not afford consumers these rights with respect to their Personal Information.  Regardless, all Personal Information will be processed in accordance with this Policy.

15.     Location of our Platform and Services

We do not warrant or represent that this Policy or the Platform’s use of your Personal Information complies with the laws of every jurisdiction.  Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours.  Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy. 

16.     For Platform Users Outside the United States

Under the (i) General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), (ii) Data Protection Act 2018, (iii) the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland (i.e., “UK GDPR”) as provided in the Data Protection Act 2018, and (iv) any other applicable data protection legislation of any country or other jurisdiction (collectively “International Data Protection Laws”) individuals have specific rights with respect to their Personal Information, or “personal data” as defined under the International Data Protection Laws.  For the purposes of this Policy, the Company operates as a data controller.  Any personal data we collect from you is processed in the United States and under the terms of this Policy.

Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing.  You may always withdraw your consent to our use of your personal data as described below.  We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.

The Data Controller is:

NAME:                       Retrove, Inc.

EMAIL ADDRESS: support@retrove.net

You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:

·      Access. You may request a copy of the personal data our Platform databases currently contain.

 

·      Automated Processing and Decision-Making.  You may request that we stop using your personal data for automated processing, such as profiling.  When contacting Company, please explain how you wish us to restrict automated processing of your personal data.  When such restrictions are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.

·      Correction or Rectification. You can correct what personal data our Platform database currently contains by accessing your account directly, or by emailing us (as provided below) to request that we correct or rectify any personal data that you have provided to us.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties. 

·      Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email (to the email provided below).  In your email, please explain how you wish us to restrict processing of your personal data.  When such restrictions are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties. 

·      Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to (to the email provided below).  When such objections are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.  

·      Portability. Upon request and when possible, we can provide you with copies of your personal data.  When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent.  Where applicable, we will ensure such changes are shared with any trusted third parties.
 

·      Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through this Platform by notifying us via email (to the email provided below).  Using the same email address associated with your Platform account, simply type the words “WITHDRAW CONSENT” in the subject line of your email.  Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data.  Where applicable, we will ensure such changes are shared with trusted third parties. 

·      Erasure. If you should wish to cease use of our Platform and have your personal data deleted from our Platform, then you may submit a request by emailing us at the email provided below.  Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted.  Where applicable, we will ensure such changes are shared with trusted third parties. 

Exercising your rights. If you are a data subject that has rights under the International Data Protection Laws, who chooses to exercise the rights listed above, you can submit a request via email at support@retrove.net.

Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below.  If you reside in a European Union member state or the United Kingdom, you may also lodge a complaint with the supervisory authority in your country.

17.     Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure.  However, we can never promise 100% security.  You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password.  If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.     

18.     Changes to this Policy

This Policy describes our current policies and practices with regard to the information we collect through the Platform. We are continually improving and adding to the features and functionality of the Platform along with the products and services we offer through the Platform. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

19.     How to Contact Us

We value your opinions and welcome your feedback.  To contact us about this Policy or your Personal Information, please contact us by email at support@retrove.net.