Date of the policy: March 15, 2022
The Right Place, Inc., a Michigan corporation ("Company" or "We") respects your privacy and are committed to protecting it through our compliance with this policy.
This Policy applies to information we, or our affiliates or subsidiaries (which in this Policy shall not be deemed to constitute a third party) collect:
- On this Website;
- In email, text, and other electronic messages between you and this Website, or you and the Company;
- Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website;
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy;
- When you interact with the Company in any way, including, but not limited to providing your data during any event registration, or during your attendance of any event that we host; or
- When you apply for a job with the Company.
This Policy does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
- Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.
Please read this 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, your choice is to not use our Website, or not interact with us. By accessing or using this Website, or interacting with us, you agree to this Policy. This Policy may change from time to time. Your continued use of this Website, and interaction with us, after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.
Children Under the Age of 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at:
125 Ottawa Ave NW, Suite 450
Grand Rapids, MI 49503
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, or individuals, who submit their information to us, including information:
- By which you may be personally identified, such as name, postal address, e-mail address, telephone number, employment-related information, or any other identifier by which you may be contacted online or offline (the "Personal Information");
- That is about you but individually does not identify you; and
- About your internet connection, the equipment you use to access our Website, and usage details.
We collect this information, including Personal Information:
- Directly from you when you provide it to us;
- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; or
- From third parties, for example, our business partners.
Information You Provide to Us.
The information, including Personal Information, we collect on or through our Website may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website;
- Information that you provide when you register for an event, or attend any event that we host;
- Records and copies of your correspondence (including email addresses), if you contact us;
- Your responses to surveys that we might ask you to complete for research purposes;
- Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website;
- Your search queries communicated to us;
- Information included in your job applications.
You also may provide information, including Personal Information, to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information, including Personal Information, We Collect Through Automatic Data Collection Technologies.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information, which may, or may not constitute Personal Information, about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website;
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information, which may, or may not constitute Personal Information, about your online activities over time and across third-party websites or other online services (behavioral tracking). Please, email us using contact information included in the Contact Information section of this Policy for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns;
- Store information about your preferences, allowing us to customize our Website according to your individual interests;
- Speed up your searches; or
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies.
- Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How We Use Your Information
We use information, including Personal Information, that we collect about you or that you provide to us, including any Personal Information:
- To present our Website and its contents to you;
- To provide you with information, products, or services that you have requested from us;
- To fulfill any other purpose for which you provide it;
- To provide you with notices about your account, including expiration and renewal notices;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- To notify you about changes to our Website or any products or services we offer or provide though it;
- To allow you to participate in interactive features on our Website;
- To allow you participate in event we host, or inform you about upcoming events;
- To review your job application;
- In any other way we may describe when you provide the information; or
- For any other purpose as provided by applicable law.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users without restriction.
- To our subsidiaries and affiliates;
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them;
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred;
- To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them;
- To fulfill the purpose for which you provide it;
- For any other purpose disclosed by us when you provide Personal Information; or
- As provided by applicable law.
We may also disclose your Personal Information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- To enforce or apply our agreements, including for billing and collection purposes; or
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by checking the relevant box located on the form on which we collect your data (the order form). You can also always opt out by checking or unchecking the relevant boxes or by sending us an email stating your request to firstname.lastname@example.org.
- Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt out by checking the relevant box located on the form on which we collect your data (the order form) or at any other time by sending us an email stating your request to email@example.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience, or other transactions.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt out by checking the relevant box located on the form on which we collect your data (the order/registration form) or by emailing us using contact information included in the Contact Information section of this Policy, or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to firstname.lastname@example.org.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website (available at: https://optout.networkadvertising.org/?c=1).
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated email address included in the Contact Information section of this Policy. However, please know we do not currently sell data triggering that statute's opt-out requirements.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
The safety and security of your 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 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.
Processing Personal Information According to the GDPR
Additionally, if the processing of your Personal Information falls within the scope of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (the “GDPR”), then such processing shall also be performed in accordance with GDPR requirements. Therefore, in addition to the above terms, Company provides you with the following information:
(a) The contact information for the Company Data Privacy Officer is provided in the Contact Information section of this Policy;
(b) Personal Information is processed only for the express purposes set forth in this Policy;
(c) Personal Information will not be transferred to processors located outside of the United States;
(d) You are entitled to:
- Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it;
- Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate Personal Information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
- Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
- Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
- Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
- Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
(e) You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
(f) You may at any time lodge a complaint with a supervisory authority located in the European Union having jurisdiction over processing; and
(g) Company does not perform automated decision-making, including profiling.
125 Ottawa Ave NW, Suite 450
Grand Rapids, MI 49503
Privacy Officer: Twayne Howard