Privacy Policy

RETHINCWORK

Last Modified: March 11, 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.

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.