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RTM Business Group Privacy Policy
Last Updated and Effective as of: January [22], 2020

RTM Business Group, LLC (“RTM”, “we”, “our” or “us”) understands that privacy is important to you. Protecting your private information is our priority. This Privacy Policy below discloses our practices regarding information collection and usage for our website https://rtmbusinessgroup.com/  (the “Website”), our RTM Congress events (“Events”) and any other websites, communications or services we provide to you (the Website, Events and other services, each individually, a “Service,” collectively, the “Services”), unless another applicable privacy policy is posted on that Service or provided on-site.

Overview:

•  We may collect Personally Identifiable Information (as defined below) from users of our Website and Services, as well as Event attendees, when it is voluntarily provided to us and use it for the purposes for which it was provided (see “Information We Collect Directly From You”).

•  We automatically collect information from users of our Website and Services for analytical purposes and to enhance our Website and Services (see “Information We Collect From You Automatically”).

•  We will not use or share your Personally Identifiable Information with anyone except as described in this Privacy Policy.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should not use the Website or the Services or participate in our Events. By accessing or using the Website or Services, or attending our Events, you agree to this Privacy Policy.  If you have questions, you can always contact us using the information in the section below titled “Contact.”

IF YOU ARE A RESIDENT OF CALIFORNIA OR NEVADA, PLEASE SEE THE SECTIONS “CALIFORNIA CONSUMER RIGHTS” OR “NEVADA PRIVACY RIGHTS” FOR SPECIFIC DISCLOSURES WITH RESPECT TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

Information We Collect Directly From You:

We may collect information, including Personally Identifiable Information, when you provide such information to us directly, such as when you submit a contact form through our Website, send us an email or resume, register for one of our Events or otherwise interact with us on the Website or Services. Your provision of your Personally Identifiable Information to us is completely voluntary. “Personally Identifiable Information” is information that specifically identifies you.  We do not collect Personally Identifiable Information unless you submit that information to us.

Categories of Personally Identifiable Information we collect directly from you include contact information including your full name, email, phone number and mailing address. We may also collect other information that you directly provide us including the country, city, state and zip code in which you are located, the name of your employer or educational institution, your job title, and marketing and communications data, such as your preferences in receiving marketing from us and the content of your communications with us.

Information We Collect Automatically:

RTM, our service providers or our third party partners may also automatically collect information from you when you interact with our Services or visit our Website through cookies and other tracking technologies.  Such information does not directly identify you as an individual and may include: 

·       Cookies and Similar Technology

We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Website or our other Services. "Cookies" are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website.   Such data may include, without limitation, the address of the websites you visited before and after you visited the Website, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Website you visit and what links you clicked on, the region where your device is located, and geo-IP data.We may use cookies to customize your visit to the Website and for other purposes to make your visit more convenient or to enable us to enhance our Services.  

·       Clickstream

As you use the Internet, a trail of electronic information is left at each website you visit.  This information, which is sometimes referred to as "clickstream data," can be collected and stored by a website's server.  Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Website.  We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Website, how visitors navigate throughout the Website and how we may tailor our web pages to better meet the needs of visitors.  This information will be used to improve our Website and our Services.

·       Site Analytics

We may work with third-party service providers who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Website.  

How We Use Your Information

We use Personally Identifiable Information and other information as described herein including for the following purposes:

  • to contact you about and provide you with our Services, including to facilitate your participation in our Events,

  • to personalize your experience with us including by storing your account information and user preferences,

  • to respond to your direct inquiries,

  • to add you to our mailing lists and send you emails from time to time,

  • to maintain the safety, security, and integrity of our Website, Services, databases and other technology assets and business,

  • for internal research for technological development and demonstration and to improve, upgrade or enhance our Website and Services,

  • for detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity,

  • to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations,

  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us,

  • as described to you when collecting your information,

  • for any additional purposes that you specifically consent to, and

  • to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by us about our Website and Service users is among the assets transferred.

 

We also reserve the right to supplement your Personally Identifiable Information with information we gather from other sources which may include information we gather from online and offline sources. Finally, we reserve the right to use and disclose information that is not Personally Identifiable Information in any manner permitted by law except as otherwise provided in this Privacy Policy.

Non-Personally Identifiable Information:

As noted above, we may collect information that is not Personally Identifiable Information (“Non-Personally Identifiable Information”).  We may aggregate or de-identify Personally Identifiable Information so that the information does not personally identify you or anyone else directly. Because Non-Personally Identifiable Information, including aggregate or de-identified information, does not personally identify you directly, we may collect, use and disclose Non-Personally Identifiable Information for any purpose permitted by law and subject to the section titled “California Consumer Notice”.  In some instances, we may combine Non-Personally Identifiable Information with Personally Identifiable Information.  If we combine any Non-Personally Identifiable Information with Personally Identifiable Information, the combined information will be treated by us as Personally Identifiable Information.

How We Share Your Information

Besides using your Personally Identifiable Information ourselves, we may send your Personally Identifiable Information and other information to other companies, affiliates and third parties in the following instances:

·       Event Sponsors and other Participants. We may share your Personally Identifiable Information with sponsors and participants of the Event in which you are participating to arrange industry meetings and networking opportunities, and to administer and further curate the Event for you.

·       Service Providers. We may share your Personally Identifiable Information with third parties who may use your information to provide us services such as website hosting, data analysis, infrastructure provision, information technology services, customer service, e-mail delivery services, Event production, auditing, and anti-fraud monitoring.  These third parties may have access to Personally Identifiable Information that is necessary to perform their functions.  

·       Legal Compliance and to Defend Our Rights. We may disclose Personally Identifiable Information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

·       Business Transfers. We may share your Personally Identifiable Information and other information with third parties in connection with a corporate restructuring, acquisition or divestiture.

·       Aggregated or Non-Personally Identifiable Information. We may share aggregated information or Non-Personally Identifiable Information with unaffiliated third parties, such as business partners, manufacturers, distributors and retailers, in a form in which means the shared information will not contain nor be linked to any Personally Identifiable Information, to improve and enhance your experience using the Website and Services and for our market research activities.  

Please note that if you specifically consent to additional uses of your Personally Identifiable Information, we may use your Personally Identifiable Information in a manner consistent with that consent.

Interactive Tools on our Website and Services

Certain features on our Website or Services may give you an opportunity to interact with us and others.  These may include review boards, blogs, message boards, messaging functionality, chat functionality, and creating community profiles.  When you use these features you should be aware that any information you submit, including your name and e-mail address, may be publicly available to others.  We are not responsible for any information you choose to submit through these interactive features and we strongly discourage you from disclosing any sensitive personal information (such as health or financial information) through these features.  If you use these features, your personal information may remain on the Website or Services even after you cease use of the Website or Services.

Security

The security of your information is very important to us.  We attempt to provide for the secure transmission of your information from your computer to our servers by utilizing encryption software. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and RTM, or information stored on the Website, our Services or our servers, will be free from unauthorized access by third parties such as hackers and your use of the Website or Services demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect.  Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personally Identifiable Information.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact section below.

Data Retention

We will retain your information for as long as your account or inquiry is active or as needed to provide you with the Website or Services and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregated data previously collected. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

Protection for Children

Our Website and Services are intended for ages 18 and over. We do not knowingly collect Personally Identifiable Information from minors.  When we become aware that Personally Identifiable Information (or other information that is protected under applicable law) from a child under 13 (or such other age as may be restricted under local law) has been collected, we will use all reasonable efforts to delete such information from our database. If you believe we might have any Personally Identifiable Information from or about a child under 13, please contact us at info@rtmbusinessgroup.com.

Other Websites and Social Networking Services

As a convenience to you, we may provide links to third party websites, apps or services from within the Website or Services. We are not responsible for the privacy practices or content of these third party sites, and by providing a link we are not endorsing or promoting such third party sites.  When you navigate away from our Website or Services, you do so at your own risk.  We encourage you to read the policies and terms of every website, app or service you visit.

The Website or Services may integrate with social networking services.  We do not control such services and are not liable for the manner in which they operate.  While we may provide you with the ability to use such services in connection with our Website or Services, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.

You should be aware that Personally Identifiable Information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others.  We are unable to control such uses of your Personally Identifiable Information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.

Opt-Out

To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at [info@rtmbusinessgroup.com]. We will process your request within a reasonable time after receipt.  Please note that if you opt out in this manner, certain aspects of the Website or Services may no longer be available to you.

Please note that, unless required by law, we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.

Changes to policy:

We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time, provided that any such modifications will only be applied prospectively. Your continued use of the Website or Services following the posting of any changes to this policy means you accept such changes.

Contact:

For questions or concerns relating to privacy, we can be contacted at: [info@rtmbusinessgroup.com].

Site Maintenance:

Our Website is maintained in the United States of America. If you are located outside the U.S., by using the Website, you authorize the export of your information to the U.S. and its storage and use as specified in this policy.

California Consumer Notice:

We collect information (some of which may also constitute Personally Identifiable Information) that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The California Consumer Privacy Act of 2018 (“CCPA”) refers to such information as “personal information.” If you are a California Consumer, or reside in a jurisdiction that provides similar rights, the CCPA or applicable law provides you with specific rights regarding your personal information. This section describes the rights that California Consumers and other consumers may have and explains how to exercise those rights. For the purposes of this section, personal information does not include (i) information that is lawfully made available from federal, state or local government records, (ii) de-identified or aggregated data or (iii) information excluded from the scope of the CCPA. To be clear the rights in this section are not intended to grant you additional rights, but just your rights under CCPA or other applicable data privacy laws.

Information We Collect; How We Collect It; How We Use It

Information about our data collection during the prior 12 months is described below. 

In addition to the purposes set forth in the above chart, each of these categories of personal information may be collected and used as otherwise described in “How We Use Your Information” above.

Categories of Personal Information:

1. Contact information and other personal identifiers such as your name, telephone number, email address, physical address, and social media usernames.
- Sources of such Personal Information:Collected from you directly through the Website and Services when you send us an email, submit a message to us through our “Contact Us” form on our Website, download our RTM Blueprint resources, send us your resume, register for or request an invitation to our Events or submit a request to speak at our Events.
- Business Purpose for such Personal Information:We use such information to respond to your communications to us, to send you marketing communications, to provide you with your requested services, to process your job application and to administer our Events, such as setting up participant meetings with our Event sponsors.
- Categories of Third Parties with whom information is shared:We share such information with our service providers, and other Event participants and sponsors.

2. Online identifiers such as cookies, mobile device IDs, IP address, type of browser and operating system.
- Sources of such Personal Information: Collected from you directly when you use the Website and Services.
- Business Purpose for such Personal Information: We use such information to better understand how the site is being used, customize our Website and Services for your use, improve our Website’s functionality, and assist in anti-fraud services.
- Categories of Third Parties with whom information is shared: We share such information with our service providers.

3. Browsing history and other information regarding internet activity.
- Sources of such Personal Information: Collected from you directly when you use the Website and Services.
- Business Purpose for such Personal Information: We use such information to better understand how the site is being used, improve our Website’s functionality, and assist in anti-fraud services.
- Categories of Third Parties with whom information is shared: We share such information with our service providers.

 4. Location information such as area code, city, state and country.
- Sources of such Personal Information: Collected from you directly through the Website and Services when you submit a message to us through our “Contact Us” form on our Website, send us your resume, or register for or request an invitation to our Events.
- Business Purpose for such Personal Information: We use such information to respond to your communications to us, to send you marketing communications, to provide you with your requested services, to process your job application and to administer our Events.
- Categories of Third Parties with whom information is shared: We share such information with our service providers, and other Event participants and sponsors.

5. Content that you submit including papers, presentations and other communications.
- Sources of such Personal Information: Collected from you directly through the Website and Services when you send us an email, submit a message to us through our “Contact Us” form on our Website, download our RTM Blueprint resources, send us your resume, register for or request an invitation to our Events or submit a request to speak at our Events.
- Business Purpose for such Personal Information: We use such information to respond to your communications to us, to provide you with your requested services, to process your job application and to administer our Events, such as setting up participant meetings with our Event sponsors.
- Categories of Third Parties with whom information is shared: We share such information with our service providers, and other Event participants and sponsors.

6. Employment information
- Sources of such Personal Information: Collected from you directly through the Website and Services when you register for or request an invitation to our Events, download our RTM Blueprint resources, or submit a request to speak at our Events or apply for a job with us.
- Business Purpose for such Personal Information: We use such information to provide you with your requested services, to process your job application and to administer our Events, such as setting up participant meetings with our Event sponsors.
- Categories of Third Parties with whom information is shared: We share such information with our service providers, and other Event participants and sponsors.

In addition to the purposes set forth in the above chart, each of these categories of personal information may be collected and used as otherwise described in “How We Use Your Information” above.


Sharing of Personal Information

RTM may disclose your personal information to a third party for a business purpose or sell personal information collected through our Website or Services subject to your right to opt-out of those sales (see “Personal Information Sales Opt-Out and Opt-In Rights”).  We may share your personal information with the categories of third parties set forth in the chart above under “Information We Collect; How We Collect It; How We Use It.”

 Disclosures of Personal Information for a Business or Commercial Purpose

In the preceding twelve (12) months, RTM has disclosed the following categories of personal information for a business or commercial purpose:

·       Personal identifiers.

·       Personal information covered by the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

·       Internet or other similar network activity.

·       Location data.

·       Professional or employment-related information.

 

See above under Information We Collect; How We Collect It; How We Use It for more information regarding each category.

Sales of Personal Information

In the preceding twelve (12) months, Company has sold the [following categories of personal information:

·       Personal identifiers.

·       Personal information covered by the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

·       Internet or other similar network activity.

·       Location data.

·       Professional or employment-related information.

 

See above under “Information We Collect; How We Collect It; How We Use It” for more information regarding each category.

Rights to Your Information

Right to Know About Personal Information Collected, Disclosed or Sold

As a California Consumer, you have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Access and Deletion Rights”), and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:

·       The categories of personal information we collected about you.

·       The categories of sources from which the personal information is collected.

·       Our business or commercial purpose for collecting or selling that personal information.

·       The categories of third parties with whom we share that personal information.

·       The specific pieces of personal information we collected about you (also called a data portability request).

 

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, and Deletion Rights”), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.  However, we maybe retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.
 

Exercising Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a request to us by visiting [rtmbusinessgroup.com].

Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above.

The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the personal information or an authorized representative of that person.

For more information about verification, see “Response Timing and Format” immediately below.

Response Timing and Format

We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing. In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will depend on the type, sensitivity and value of the information, including the risk of harm to you posed by any authorized access or deletion. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request (and will not be made more than twice in a 12-month period). If we cannot comply with a request, or cannot fully comply with a request, the response we provide will also explain the reasons we cannot comply.

Personal Information Sales Opt-Out and Opt-In Rights

You have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 and less than 16 years of age, or the parent or guardian of a consumer less than 13 years of age.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following internet web page:

[HYPERLINKED URL with the title "Do Not Sell My Personal Information"]

Alternatively, you may submit an opt-out request by contacting us at info@rtmbusinessgroup.com.

If you use an authorized agent to exercise the right to opt-out, you must provide the authorized agent written permission to do so, and we may deny the request if the authorized agent does not submit proof that it has been authorized by you to act on your behalf. You may change your mind and opt back in to personal information sales at any time by [OPT-IN INSTRUCTIONS OR URL LINK]

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights, including, but not limited to, by:

  • Denying you goods or services.

  • Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Providing you a different level or quality of goods or services.

  • Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

California “Shine the Light”

Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address and mailing address and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at [info@rtmbusinessgroup.com]. If you do not want your personal information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at [info@rtmbusinessgroup.com]. 

Nevada Privacy Rights

If you are a Nevada resident, you have the right to request that we do not sell your covered information (as those terms are defined in N.R.S. 603A) that we have collected, or may collect, from you. We do not sell your covered information, however, if you would like to make such a request you may do so by contacting us at [info@rtmbusinessgroup.com]. 

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