Last Updated: February 10, 2020
Understory, LLC d/b/a Rali (“Rali”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information that Rali (also referred to as “we,” “us” or “our”) may collect from you or that you may provide when you visit https://rali.io and https://www.getrali.com (collectively, our “Website”) or use our Rali solution, services or platform, as well as our practices for collecting, using, maintaining, protecting and disclosing that information.
This policy applies to information we collect through our Website, or through other uses of our Rali solution, services or platform.
This policy does not apply to information collected by us offline or through any other means or any third party.
Please note that in order to use our Website or the Rali solution, services or platform, you authorize us to transfer your personal information across national borders and to other countries, including the United States, where we or our customers, licensees or service providers operate. The privacy protections and rights of authorities to access your information in these countries may not be equivalent to those in your country. We will only transfer your personal information to these countries where permitted to do so by law and we will take steps intended to ensure that your personal information continues to receive appropriate protections.
If the content or information that you submit to us via our Website or the Rali solution, services or platform contains personal information of other individuals, you must be legally permitted to share any such personal information with us.
Please note that Rali does not knowingly collect, use, or disclose personal information from children under the age of 16 without verifiable parental consent. If you are under 16 years of age, please do not register with any product or services offered by Rali to include but not be limited to the Rali solution, services or platform, unless your parent provides consent as part of the child account creation process. If at any time a parent needs to access, correct, or delete data associated with their child’s account, they may contact us directly using the details set out below. If we learn that we have collected or received the personal information of a child under 16 years of age, we will take steps to delete the information as soon as possible.
What information do we collect?
RALI ID, REGISTRATION, AND CUSTOMER SUPPORT
When you use or register to use our Website or the Rali solution, services or platform, we collect an email address and a display name. You may elect to provide us with additional personal information including your first and last name. In addition, you may provide us with an avatar image or other picture to be used with your display name within the Rali platform. Please note that we endeavor to minimize the personal information that we collect to only that information that we deem necessary to provide you with a quality experience and service.
In addition, we collect information when you use our Rali solution, services or platform. This information may be anonymous or it may be associated with you and it includes the following:
- IP address;
- Type of browser and device (including device ID);
- Geolocation information; and
- Use and navigation of our Rali solution, services or platform (collected through cookies and similar technologies).
We may also send you emails that include technologies that tell us whether you have received or opened the email or clicked a link in the email. If you do not want us to collect this information, you can opt out or unsubscribe from receiving emails from us.
RALI SOCIAL NETWORKING PAGES AND SOCIAL SIGN-ON SERVICES
You can sign in to the Rali solution using a social networking account, such as a Facebook account. Where you give appropriate permissions, we will receive information about you provided by the applicable social network account including, for example, your name or token ID.
How do we use the information we collect and what are the legal bases for our uses?
We use the information we collect about you for the following purposes:
- To fulfill a contract, or take steps linked to a contract: this is relevant where you register to use the Rali solution, services or platform. This includes:
- Providing you or the entity that you are employed by or affiliated with the Rali solution, services or platform;
- Verifying your identity;
- Taking payments, if applicable;
- Sending you communications (for example, in application notices relating to use of the Rali solution or its features, and data or scores relating to content); and
- Providing customer service or support.
- As required to conduct our business and pursue our legitimate interests, including but not limited to:
- Providing you with the Rali solution, services or platform for which you have registered and any other products and services you have requested;
- Analyzing your use and measuring effectiveness of our Rali solution, services or platform to better understand how they are being used so we can improve them and engage and retain users;
- Sending you information about our products and services or other products or services that we determine may be of interest to you;
- Using automated systems to analyze your content using techniques such as machine learning in order to improve our services and the user experiences;
- Diagnosing problems in our Rali solution, services or platform;
- Investigating and responding to any comments or complaints that you may send us; and
- In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of information in connection with legal process or litigation).
- Where you give us your consent or otherwise consistent with your choices:
- Sending you information about our products and services, and sharing your information with third parties for their own purposes (where your consent is required);
- Placing cookies and using similar technologies on our Website, within our Rali solution, services or platform and in email communications, in accordance with our Cookies Policy, and the information provided to you when those technologies are used;
- Accessing information stored on your device relating to your use of, and engagement with, the Rali solution, services or platform;
- Using automated systems to analyze your use of content such as machine learning in order to improve our services and the user experience; and
- On other occasions where we ask you for consent, we will use the information for the purposes which we obtain consent for.
- For legal reasons and other lawful purposes:
- Responding to requests by government or law enforcement authorities conducting an investigation;
- To detect, prevent, or otherwise address fraud, security or technical issues (e.g., to confirm that software is genuine and properly licensed);
- For other purposes as we determine to be required by applicable law; or
- For other purposes that we determine to be lawful.
Do we share your personal information?
SHARING WITH OTHER DATA CONTROLLERS
We will share your personal information within our company for the purposes identified above. Only those employees or contractors that require access to your information in order to deliver our service or provide you and other users with high quality services will have access to your information.
We will share personal information with companies, organizations or individuals that we license the Rali solution, services or platform to in order to provide our Rali solution. In many instances, this means that we will be sharing your information with a company or entity that you are employed by or affiliated with. In other instances, this means that we will be sharing certain information (for example, your display name) with other users of our products or services. In each of these instances, your information will be used only for the purposes directly related to use of the Rali solution, services or platform, as permitted under any agreement or contract with Rali, or as otherwise permitted by applicable law. Excepting personal information collected by any third party outside of the Rali solution, services or platform, personal information collected by or through the Rali solution, services or platform may not be used by any third party for advertising or marketing purposes without our express written authorization and the express consent of the individual that the personal information relates to.
SHARING WITH DATA PROCESSORS
We will also share your personal information with companies that help us to run our business and provide our products and services by processing personal information on our behalf and at our direction. Such companies include providers of customer support services, communications service providers including providers or in-application communications services, payment processing services, fraud monitoring and prevention service providers, email, social media, marketing platforms and other similar service providers, and hosting services.
We may also share your personal information:
- When you agree to the sharing;
- When we are required to provide information in response to a subpoena, court order, or other applicable law or legal process;
- When we have a good faith belief that the disclosure is necessary to prevent or respond to fraud, defend our products or services against attacks, or protect the property and safety of our company, our employees, our customers and users, or the public; or
- If we merge with or are acquired by another company or if all or a substantial portion of our assets are acquired by another company, your information will likely be disclosed to our advisers and any prospective purchaser’s advisers and will be one of the assets that is transferred to the new owner.
We may also share or publish aggregate information that doesn’t specifically identify you, such as statistical information about our customers or the users of the Rali solution, services or platform.
Is my personal information displayed anywhere on the Rali solution, services or platform?
Features of the Rali service allow you to post comments or submit content for others to see. In addition, the display name that you provide upon registration with the Rali service will be included and displayed with any comments or content that you submit to the Rali solution, services or platform. When using the Rali service, you have the option to create a user profile within the Rali service that includes additional personal information such as, for example, your first and last name and your image or an avatar. This optional information, if you elect to include such information in your profile, may be displayed to other users within the Rali service. Please note that in some instances, you can limit who can see what you post or share; however, in other instances, all posts, comments or content that you share can be seen by other users of the Rali solution, services or platform. Please be careful when you share your personal information or provide comments or content. Do not share, post, comment or submit any content that you do not want publicly known or displayed.
Please also note that if your use of the Rali services or platform is through a company or entity that you are employed by or affiliated with, and if such company or entity has invited you to participate in sharing, submitting, viewing, editing, or commenting on content, you may not be able to delete your contributions because the company or entity that you are employed by or affiliated with may have ownership and control over the posts, comments and content you have submitted. If you have questions or concerns about this, please contact the company or entity you are employed by or affiliated with, or, please contact us and we will work to try to resolve your concerns.
Is my personal information secure?
We understand that the security of your personal information is important. We provide reasonable administrative, technical, and physical security controls to protect your personal information. However, despite our efforts, no security controls are 100% effective and we cannot ensure or warrant the security of your personal information.
The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out personal information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Where we store your personal information?
In those instances where we are providing and hosting the Rali solution, services or platform, your personal information and files are stored on our servers or on servers that we lease and control.
Do we transfer your personal information across national borders?
We may transfer your personal information across national borders to other countries in compliance with applicable laws.
What rights do I have in respect of my personal information and how can I exercise these rights?
Under the law of some countries, you may have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; to obtain the personal information you provide to us in a structured, machine readable format, and to ask us to share or transfer this information to another controller.
In addition, you can object to the processing of your personal information in some circumstances (in particular, where we don’t have to process the information to meet a contractual or other legal requirement, or where we are using the information for direct marketing).
Please note that these rights may be limited. For example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information that we are required by law to keep or that we have a compelling legitimate interests in keeping (such as fraud prevention purposes), we may not be able to fulfill your request.
To exercise any of these rights (including deactivating your Rali account), you can get in touch with us – or our data protection officer – using the details set out below. Please note that while your account with Rali is active, you can always access your Rali account for the purposes of exercising certain rights including, for example, correcting any personal information that is erroneous and deleting optional personal information that you have previously entered.
If you have unresolved concerns, please contact us directly using the details set out below. If you continue to have unresolved concerns, you have the right to report them to an EU or other data protection authority where you live, work or where you believe a potential violation may have occurred.
How long do we retain your information?
When you register with the Rali service, we process and maintain the personal information we have about you for as long as you are an active user of our products, services or applications. When you close your account, we begin deleting certain personal information that we no longer have a business reason to retain. However, we typically retain personal information related to our contract and business transactions with you for up to seven (7) years after your last interaction with us or, alternatively, as long as our legal representatives advise us is necessary.
Where we process personal information for marketing purposes or with your consent, we process the information until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a permanent record of the fact that you have asked us not to send you direct marketing or to process your information so that we can respect your request in future.