RETHINC PRIVACY POLICY

 

Last Modified: March 25, 2024

 
INTRODUCTION
This Privacy Policy explains how Rethinc (“Rethinc”; “Company”; “we”; “us”; or “our”) collects and
processes information through our websites at www.rethinc.us and www.rethinc1.bubbleapps.io
(collectively, the “Website”); through our web-based application, RethincWork (the “App” or
“RethincWork”); and through other services that clients, participants in our programs, visitors to our
Website and users of our App may access (the “Services”). The Website, App and Services are
collectively called the “Properties.”
 
Please read this Privacy Policy carefully to understand our policies and practices regarding such
information. By accessing or using the Properties, you agree to this Privacy Policy. If you do not agree
with our policies and practices, you should not use the Properties or otherwise provide us with Personal
Data.
 
Our Website and App are provided from and hosted in the United States. You understand that data stored
in the United States may be subject to lawful requests by the courts or law enforcement authorities in the
United States. 
 
OVERVIEW
• ​We collect Personal Data (as defined below) from users of our Properties—including through
questionnaires and surveys (collectively, “Surveys”) that we administer on behalf of our
clients—when it is provided to us voluntarily, and we use it for the purposes for which it was
provided.
• We automatically collect information from users of our Website and App for analytical purposes
and to provide and maintain the Properties.
• We will not use or share information we collect from you with anyone except as described in this
Privacy Policy.
 
INFORMATION WE COLLECT DIRECTLY FROM YOU
“Personal Data” is information that identifies, relates to, describes, is reasonably capable of being
associated with, or could reasonably be linked, directly or indirectly, with you. Such information may also
be referred to as “personal information” or “personally identifiable information” under applicable laws,
which may provide their own definitions. We may collect information, including Personal Data, when you
provide such information to us directly, such as when you send us an email, create an account with
us, participate in a survey through RethincWork (as described below in the Survey Data section), or
otherwise interact with us on the Properties. 
 
Types of Personal Data we may collect directly from you on the Website include contact information,
such as your name, email address, and telephone number. We may also collect other information that you
directly provide us, including marketing and communications data (e.g., your preferences in receiving
marketing from us), and your consent to accept cookies.

NON-PERSONAL DATA
We may collect information that is not Personal Data (“Non-Personal Data”). We may also aggregate or
de-identify Personal Data so that the information does not personally identify you or anyone else directly,
and is therefore considered Non-Personal Data. Because Non-Personal Data, 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.
 
• ​SURVEY DATA / RETHINCWORK
 
RethincWork is a component of the platform associated with the Services we provide to our clients to
administer, analyze or otherwise use data from Surveys (“Survey Data”). Survey Data may include the
following:
• Company Data – Provided by our clients, and may include job titles, email addresses, and
employees’ first and last names.
• Demographic Data – Self-reported data that you provide, which may include factors of race,
ethnicity, sexuality, gender and disability status.
• User Responses to Inclusion Survey – Your individual responses to the inclusion survey that
forms part of our Services.
Rethinc does not provide a digital framework, whether within the Properties or offline, that enables a
client or other organization to track, access, edit or delete the unprocessed Survey Data of an employee.
 
By providing Survey Data, you hereby consent to the Rethinc’s disclosing your Survey Data
through the RethincWork platform and making it available, in aggregated and anonymized form,
to the client that has engaged our Services for the collection of your Survey Data. You further agree
that, as a RethincWork user, you assume full and sole responsibility for any Personal
Data that you provide through RethincWork or the Properties, and Rethinc shall bear no
responsibility nor be subject to any liability arising out of or related to the use or disclosure of
Personal Data that you provide.
 
INFORMATION WE COLLECT AUTOMATICALLY
We, our vendors, or our third-party partners may automatically collect information from you when you
visit our Website. Such information does not directly identify you as an individual and may include:
 
• Cookies and Similar Technology
 
“Cookies” are pieces of information that may be placed on your device by a service for the purpose of
facilitating and enhancing your communication and interaction with that service. We may use cookies
(and similar items such as clear gifs, web beacons, tags, pixels, and similar technologies) through
our Properties to customize your experience, to analyze how you use our Properties and for other
purposes to make your visit or use more convenient, to manage your account or to enable us to enhance
our Properties.  We do not use cookies or similar items to automatically retrieve personally identifiable
information from your device without your knowledge, but we may use them to store your login
credentials if you create an account through our Services.
 
Based on your web browser, you may have the ability to accept or decline cookies. Most web browsers
automatically accept cookies, but you can usually modify your browser settings to decline cookies if you
prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of
the Properties. Further information on cookies is available at www.allaboutcookies.org.

 
• Clickstream Data
 
As you use the Internet, a trail of electronic information is left at each website you visit. This information,
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 Properties,
how visitors navigate throughout the Properties and how we may tailor our Website and App to better
meet the needs of visitors and participants.
 
• Website 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 the Website. One such
provider is Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google
Analytics uses cookies to help analyze how users use the Website. The information generated by these
cookies about your use (including your IP address) will be transmitted to and stored by Google on servers
in the United States. Google will use this information for the purpose of evaluating your use of the
Website, compiling reports on activity for its staff, and providing other services relating to web page
activity and internet usage. Google may also transfer this information to third parties where required to do
so by law, or where such third parties process the information on Google's behalf. You may refuse the use
of cookies by selecting the appropriate settings in your browser. By using the Website and accepting
cookies, you consent to the processing of data about you by Google in the manner and for the purposes set
out above. Please refer to the currently available opt-outs for Google Analytics by
visiting https://tools.google.com/dlpage/gaoptout/. You may obtain additional information about Google
Analytics by visiting the section titled "How Google uses information from sites or apps that use our
services,” located at www.google.com/policies/privacy/partners/.
 
Please note that under the laws of some jurisdictions, your IP address may be considered Personal Data.
However, we use IP addresses solely for the purposes described in this section and do not attempt to
identify you personally using such information.
  
HOW WE USE YOUR INFORMATION
We may use Personal Data and other information as described herein including for the following
purposes:
 
• to contact you about our Services
• to personalize your experience with us
• to respond to your direct inquiries
• to send you email related to any communications to which you have subscribed
• to add you to our mailing lists and send alerts or marketing emails from time to time
• to create and administer your participation in RethincWork or other Services
• to maintain the safety, security, and integrity of our Properties and your account,
• to provide the Services to our clients,
• to respond to law enforcement requests and as required by applicable law, court order, or governmental
regulations
• as described to you at the point of collection of your information, 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 Properties’ users is among the assets transferred

  
HOW WE DISCLOSE YOUR INFORMATION
Besides processing your Personal Data ourselves in connection with our Services, we may send your
Personal Data and other information to other companies, affiliates, and third parties in the following
instances:
 
• Service Providers and Vendors. We may disclose your Personal Data (but not Survey Data) to third parties
who may use your information to provide us services such as website hosting, data analysis, infrastructure
provision, information technology services, customer service, email delivery services, auditing, and anti-
fraud monitoring. These third parties may have access to Personal Data that is necessary to perform their
functions. 
 
• RethincWork. We may allow clients to view Survey Data, collected on their behalf, that is stored in an
aggregated and anonymized form on the RethincWork platform. Clients do not have access to
unprocessed Survey Data associated with individuals who have provided responses to Surveys through
the App.
 
• Legal Compliance and to Defend Our Rights. We may disclose Personal Data 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 disclose your Personal Data and other information with third parties in
connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of
some or all of the assets of the Company, whether as a going concern or as part of bankruptcy, liquidation,
or similar proceeding, in which information held by the Company about our Website users is among the
assets transferred.
 
• Aggregated or Non-Personal Data. We may disclose aggregated information or Non-Personal Data with
unaffiliated third parties, such as business partners, in a form in which the shared information will not
contain nor be linked to any Personal Data, to improve and enhance your experience using the Properties,
and for our market research activities.   
 
Please note that if you specifically consent to additional uses of your Personal Data, we may use your
Personal Data in a manner consistent with that consent.
 
LINKS TO OTHER SITES AND SOCIAL MEDIA SERVICES
We may create links to other websites that we think may be of interest to you, such as providers of
various products, services and information. We may also provide links that allow you to send or forward a
post or other content from our Properties through or to a third-party social media site or other means of
electronic communication, such as an email or text messaging service.  We do not endorse any other
websites, providers or services by providing such links, and our privacy policy applies only to your use of
our Properties. We are not responsible for the privacy policies of any websites and services we link
to through our Properties, and you should read the privacy policies of each site you visit to determine
what information that site may collect about you.
 
SOCIAL NETWORKING SERVICES

The Properties 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 Properties, 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 Personal Data which you voluntarily include and transmit online in a publicly
accessible blog, forum, social network or otherwise online may be viewed and used by others.  We are
unable to control such uses of your Personal Data, and by using such services you assume the risk that the
Personal Data provided by you may be viewed and used by third parties.
 
DATA RETENTION
We will retain your information for so long as needed for us to manage and provide our Services to our
clients during the term of their engagement. If we delete some or all of your Personal Data, we may in
some instances continue to retain and use de-identified or aggregate data previously collected, to the
extent permitted under applicable law.
 
HOW WE PROTECT YOUR INFORMATION
The security of your information is very important to us. We attempt to provide for the secure
transmission of your information from your devices to our servers. However, due to the inherent open
nature of the Internet, we cannot guarantee that communications between you and Rethinc, or information
stored on Properties, or our servers, will be free from unauthorized access by third parties such as hackers,
and your use of the Properties demonstrates your assumption of this risk. We have put in place reasonable
physical, electronic, and managerial procedures to safeguard the information we collect.  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 at appsupport@rethinc.us.
 
YOUR PRIVACY RIGHTS
In certain jurisdictions, you may have rights regarding the Personal Data that you have provided or that
we have collected about you. Visitors to our Properties or users of our Services who reside in the
EU/EEA, the United Kingdom, or Switzerland may have additional rights set forth in the EU/EEA,
UNITED KINGDOM AND SWITZERLAND RIGHTS section, below.
 
For clarity, these rights are granted only to the extent that (a) you are a resident of a jurisdiction that
grants these rights and (b) we are obligated to grant the rights stated below under applicable laws with
respect to your Personal Data. The rights in this section are not intended to grant you additional rights, but
only your rights under applicable laws in your jurisdiction.
 
You may have the following rights with respect to your Personal Data, subject to our ability to verify your
identity:
 
• Right to be informed of the purpose of collection, and details of any third party that will receive Personal
Data and for what purpose.
• Right to access to Personal Data about you that we maintain, subject to our right to deny such access to the
extent permitted by law.
• Right to correction of Personal Data.
• Right to deletion of Personal Data.
 
If you have questions about these rights or would like to assert any of the rights available to you, please
contact us at appsupport@rethinc.us.
 

CHANGES TO OUR PRIVACY POLICY
We reserve the right, at our discretion, to update this Privacy Policy at any time and will notify you of any
material changes to the way in which we treat Personal Data by posting an updated Privacy Policy or
other notice on relevant areas of our Properties. Any updated version of this Privacy Policy will be
effective immediately upon posting unless otherwise specified. Your continued use of the Properties after
the effective date of the revised Privacy Policy will constitute your consent to those changes. However,
we will not, without your consent, use your Personal Data in a manner materially different from what was
stated at the time your Personal Data was collected. We encourage you to periodically review the
Website or App for the latest information on our privacy practices.
 
CHILDREN’S PRIVACY
Our Properties are intended for users ages 18 and over, and we do not knowingly collect Personal Data
from children under the age of 16 without the consent of a parent or legal guardian. If we become aware
that Personal Data (or other information that is protected under applicable law) from a child under 16 has
been collected without consent, we will use all reasonable efforts to delete such information from our
databases. If you believe we might have any Personal Data from or about a child under 16 that was
obtained without consent, please contact us at appsupport@rethinc.us.
 
CROSS-BORDER DATA TRANSFERS:
If you submit Personal Data to us, that information may be processed in a jurisdiction where privacy laws
may be less stringent than those in your country of residence. By submitting your Personal Data to us,
you agree to the transfer, storage, and processing of such information in foreign jurisdictions including,
but not limited to, the United States. Please note that Personal Data transferred to the United States is
subject to access by law enforcement. Where applicable, we may use model clauses approved by the laws
of your jurisdiction (such as Standard Contractual Clauses approved by the European Commission) for
cross-border data transfers.
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. Please note that Personal Data transferred to the United States is subject to access by law
enforcement. If you have any questions about the transfer of your data to the U.S., please contact us at
appsupport@rethinc.us.
 
CONTACT US
If you have any questions or comments about this Privacy Policy, please contact us by email at
appsupport@rethinc.us.
EU/EEA, UNITED KINGDOM AND SWITZERLAND RIGHTS
IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, UNITED KINGDOM OR
SWITZERLAND, THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF
YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
Legal Basis:
We will only use your Personal Data, as that term is defined under the General Data Protection Regulation
(“GDPR”), when the law allows us to. Most commonly, we will use your Personal Data in the following
circumstances:
 Where we need to perform the contract we are about to enter into or have entered into with you.

 Where it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests.
 Where you have consented to a certain use of your Personal Data.
 Where we need to comply with a legal or regulatory obligation.
To the extent permitted under applicable laws, we will also process, transfer, disclose, and preserve
Personal Data when we have a good faith belief that doing so is necessary.
Data controller:
Rethinc is the data controller of all Personal Data collected through our Website. To contact us, please see
the section titled Contact.
If you are situated in the UK or EU and have any complaints regarding our privacy practices, you have
the right to make a complaint at any time to your local supervisory authority. We would, however,
appreciate the chance to deal with your concerns before you approach your supervisory authority, so
please contact us in the first instance. If you have a complaint, please contact our privacy manager here
appsupport@rethinc.us.
Data processor:
In some cases, we act as a processor on behalf of our business customers who use our Services. This
means that we are a service provider that processes Personal Data on behalf of and on the instructions of
our business customers. Our business customers act as data controllers for such data. These business
customers: (a) determine the purposes for which we process Personal Data; and (b) are responsible to
applicable data subjects for the processing of their Personal Data.
As data controllers, our business customers are responsible for disclosing the rights of data subjects with
respect to their Personal Data and other information regarding the collection and use of that Personal
Data, in accordance with GDPR and other applicable laws requiring such disclosures. If you wish to
exercise any of your rights related to such information under the GDPR, please contact the relevant
business that acts as the data controller of your Personal Data.
Provision of Personal Data and failure to provide Personal Data:
Where we need to collect Personal Data by law or under the terms of a contract we have with you, and
you fail to provide that data when requested, we may not be able to perform the contract we have or are
trying to enter into with you (for example, to provide you with our Services). In this case, we may not be
able to provide certain Services to you.
Withdrawing your consent:
If we are relying on your consent to process your Personal Data, you have the right to withdraw your
consent at any time by contacting us at appsupport@rethinc.us.
Data Transfer:
We may transfer Personal Data from the EU to the United States and other countries, some of which have
not been determined by the European Commission to have an adequate level of data protection. Where we
use certain service providers, we may use specific contracts approved by the European Commission
which give Personal Data the same protection it has in Europe. For more information about how we
transfer your data, please contact us at appsupport@rethinc.us.

Data Subject Rights:
If you are a situated in the EU, under the GDPR, as a data subject, you have the right to:
 Request access to your Personal Data (commonly known as a "data subject access request"). This
enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully
processing it.
 Request correction of the Personal Data that we hold about you. This enables you to have any
incomplete or inaccurate data 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 Data. This enables you to ask us to delete or remove Personal
Data 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 Data where you have successfully exercised your right to object to
processing (see below), where we may have processed your information unlawfully, or where we are
required to erase your Personal Data 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 Data 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 Data 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 Data. This enables you to ask us to suspend the
processing of your Personal Data 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 Data to you or to a third party. We will provide to you, or a
third party you have chosen, your Personal Data 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 Data.
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.
To exercise your rights under the GDPR, please contact us at appsupport@rethinc.us. Please note that for
you to assert these rights, we may need to verify your identity to confirm your right to access your
Personal Data. This is a security measure to ensure that Personal Data is not disclosed to any person who
has no right to receive it. To verify your identity, we may need to gather more Personal Data from you
than we currently have.