Privacy Notice

Effective Date: October 4, 2021

Record360 Inc., (“Record360,” “we,” “us,” or “our”) knows your, and your customer’s, Personal Information is important to you (“you,” or “your,”). We appreciate the trust you place in us when you visit the R360 Platform and use our services. As a result, we process the Personal Information we receive from you responsibly and in accordance with applicable laws and regulations. This privacy notice describes how we process the Personal Information collected when you access this website (“Website”) or our mobile application (“Mobile App”). Together the Website and Mobile App are the Record360 platform (“R360 Platform”) When you leave the R360 Platform, this privacy notice no longer applies. Any subsequent website, application or service you access will have its own privacy notice and other applicable terms. 

 

By accessing the R360 Platform you signify that you agree to be bound by R360 Platform terms and conditions and this privacy notice which are located at the bottom of each Website page or in the Mobile App. If you do not agree to R360 Platform terms and conditions or this privacy notice, you must discontinue use of the R360 Platform.

 

PLEASE NOTE: If you are entering Personal Information on behalf of your customer into the R360 Platform, you must deliver your own privacy notice (as a Data Controller) to your customer, which incorporates this R360 Platform Privacy Notice as a your Data Processor.

Information We Collect and How We Use It

When you visit the R360 Platform, we collect: (1) technical information that is used to deliver the contents and services on the R360 Platform and for other purposes as described below, and (2) information that you, or your customers, voluntarily submit (“Personal Information”).

 

Our primary purpose in collecting Personal Information is to provide services, personalize your user experience and for internal operations, including troubleshooting, data analysis, and testing of the R360 Platform. We may also use third-party service providers, partners, or affiliates to help us operate the R360 Platform, or administer activities on our behalf, such as events or marketing campaigns. It may be necessary to provide or allow access to yours, or your customer’s, Personal Information to these third-party service providers, partners, or affiliates for those purposes.

Information We Collect From You

We collect a variety of information that you provide to us. The specific types of information we collect will depend upon your engagement with the R360 Platform. For example, we collect information from you when you:

 

  • Request information about R360 Platform content and services, or
  • Any other information you choose to directly provide to us in connection with use of the R360 Platform. For example, if you, or your customer, decides to use the services offered by us we will collect customer contact information with proof of identity, such as a an government identification card before your customer can use R360 Platform services.

 

Form Submissions and User-Initiated Communication. If you fill in forms on the R360 Platform or communicate with us via phone, email, or otherwise, we may collect your contact information, as well as other information you may provide to us, such as customer service interactions with us.

Information We Collect Through Automated Means

We may automatically collect certain information based upon your behavior on the R360 Platform. We use this information to conduct internal research on demographics, interests, and behavior to better understand who is visiting the The R360 Platform, for marketing purposes and to improve our related services. Whenever possible, the collected data is de-identified, aggregated and/or anonymized.

 

Device Information. When you access the R360 Platform, we may collect device information that could be used to identify you or your device and may provide us with your location. These identifiers may include IP address, hardware and software information, browser type, device event information, crash data, cookie data, and the pages you have viewed or engaged with before or after accessing our R360 Platform.

 

User Activity Information. We may record information about your behavior on the R360 Platform. This includes details about how you use the R360 Platform, such as content accessed, time viewed, links clicked, referring/exit pages, date/time stamp, and clickstream data.

 

Cookies and Similar Technologies. The R360 Platform may use cookies, pixel tags, and local storage (such as data caches and server logs) to distinguish you from other users of our Services. Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies.

We may use certain cookies, as described here in our privacy notice, that you agree to when you visit the R360 Platform and in the case of some cookies, for legitimate interests of delivering and optimizing the The R360 Platform (where the cookie delivers essential functionality or for security reasons). Any cookies we may use on the R360 Platform may include session cookies. A session cookie expires when you close your browser. We will use this information to make our R360 Platform more relevant to your interests. 

 

You will be given the opportunity to opt-out of non-essential cookies via our cookie management tool that is available to you at the bottom of each Website page.

Our Use of Your Information

We use your information for various purposes depending on the types of information we have collected from you, in order to:

  • To provide the content and services available on the R360 Platform,
  • Respond to your request for information and provide you with more effective and efficient customer service,
  • Contact you by email, phone, or mail regarding our services, and other subjects that we think may be of interest to you (only with your consent),
  • Help us better understand your interests and needs, and improve our R360 Platform,
  • Secure our R360 Platform and resolve crashes and other issues being reported,
  • Comply with any laws and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others,
  • Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others,
  • Where necessary to take legal action (including the commencement and carrying out of legal and court proceedings), and
  • to notify you about changes to our R360 Platform terms of service or privacy notes.

Aggregated Data. We may aggregate information collected through our R360 Platform so that the information can no longer be linked to you or your device. We may use the combined information for any internal purpose, including without limitation for marketing purposes.

Sharing Information with Third Parties

We share your Personal Information with the following types of third parties:

 

Affiliates and Subsidiaries. We may share information we collect within our family of companies to deliver our services to you, and to enhance our services and your customer experience.

Service Providers. We share your information with select third parties who assist us to operate the R360 Platform, conducting our business, and providing services to us on your behalf. They provide a variety of services to us, including marketing, sales, database management, research, customer service, data storage, security, fraud prevention, and legal services. They have access to perform these services but are prohibited from using your information for other purposes. 

 

A list of current sub-processors is located on the Website in the footer of the home page. We will provide notice if this list of sub-processors changes. If you do not agree with the changes you may terminate your use of the R360 Platform in accordance with the R360 Platform terms of use.

 

Protection of Us and Others. By accessing the R360 Platform, you acknowledge and agree that we may also release your information when required by law or in good faith when we believe that disclosure is reasonably necessary to comply with the law or legal process (e.g., a subpoena or court order), enforce our privacy notice or other contracts with you, including investigations of potential related violations, or to protect ours or others’ rights, property, or safety, respond to claims that any content violates the rights of third parties; or to respond to your requests for customer service. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.

 

Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with applicable restrictions.

 

Partners. From time to time, we may engage in marketing and promotional activities with other brands (our “Partners”), which we think will appeal to our customers and potential customers. Partners may be provided with non- identifying or aggregate information indicating the demographic information of visitors to the R360 Platform, and opportunities to market to select segments of our customer base indirectly. When we share aggregate customers data, we do so in a way that it cannot identify you. 

 

PLEASE NOTE: We do not sell your Personal Information to any third-parties.

Marketing Communications

You may instruct us not to use your contact information to contact you regarding our services, promotions, or other events that might appeal to your interests. You can also opt out by following the instructions located at the bottom of any commercial emails you may receive.

Privacy Notice for Residents of Certain U.S. States

Some U.S. state laws provide state residents with additional privacy rights. We are not currently subject to any U.S. state law which grants its residents with additional privacy rights, including the California Consumer Protection Act.

Do Not Track Disclosure

Regulatory agencies such as the U.S. Federal Trade Commission have promoted the concept of Do Not Track as a mechanism to permit Internet users to control online tracking activity across websites through their browser settings. 

We currently do not process or comply with any web browser’s “do-not-track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit our Sites or use our Services.

Children’s Online Privacy Protection Act Compliance 

Our Services are all directed to people who are at least 16 years old or older.

 

We do not knowingly collect any “Personal Information” (as defined by the U.S. Children’s Online Privacy Protection Act) from anyone under 16 years of age without valid parental consent. If we become aware that we have collected such Personal Information without parental consent, we will take reasonable steps to delete it as soon as possible.

We also comply with other age restrictions and requirements in accordance with applicable local laws.

Retention of Information

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

Protection of Information 

We implement a variety of security measures designed to protect the safety of your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction when you enter or submit your Personal Information on the R360 Platform. However, no Internet or email transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to us via the Internet.

Yours (and Your Customer’s) Data Subject Rights

You have the following rights associated with the processing of your personal information:

  • The right to access to your data
  • The right to update or correct your data
  • The right to object to the use of your data
  • The right to restrict the use of your data
  • The right to transfer your data to another data controller
  • The right to the erasure of your data
  • The right to withdraw consent
  • The right to non-discrimination related to the exercising of your rights under the GDPR and CCPA
  • The right to obtain information about the personal data we have collected from you and sold or disclosed to other subjects, if you are a California resident
  • The right to opt-out from sales of your personal information to third parties
  • In addition, if you are a California resident, you have the right to request from us to disclose to you the following:
  • The categories of personal information we have collected about you
  • The categories of sources from which the personal information is collected
  • The business or commercial purpose for collecting or selling your personal information
  • The categories of third parties with whom we share personal information
  • The specific pieces of personal information we have collected about you

How Can You (or Your Customer’s) Exercise Data Subject Rights

You may submit your requests to exercise your (or your customer’s) data subject rights to:

  • Email: support@record360.com
  • Address: 1333 North California Blvd., Suite 448, Walnut Creek, CA 94596
  • Cookie Banner: Submit request via automated web form located at the bottom of each page on the Website.

Please note that we may ask you to verify your identity before responding to your requests. You (or your Customer) have the right to complain to a Data Protection Authority about our collection and use of Personal Information. For more information, please contact your local data protection authority.

Third Party Links and Websites 

This Privacy Notice does not address, and we are not responsible for, the privacy practices of any third parties, including those that operate websites to which the R360 Platform links. The inclusion of a link on the R360 Platform does not imply that we or our affiliates endorse the practices of the linked website. 

Co-Branded Websites

In the event that our Website links to other websites that include our branding, this Privacy Notice does not apply to those other websites. Visitors to those websites are advised to carefully read the notices on those individual websites. 

Change of Ownership

In the event of a change in ownership, or a merger with, acquisition by, or transfer or sale of all or a portion of our assets to, another entity, we reserve the right to transfer all of your Personal Information, including email addresses, to that entity. We will use reasonable efforts to notify you of any such transfer to an unaffiliated third party (by a posting on our homepage, or by email to your email address that you provided to us, as chosen by us in our discretion).

Changes to Our Privacy Notice 

We reserve the right to amend this privacy notice at any time to reflect changes in the law, our data collection, use or sharing practices or advances in technology. We will make the revised Privacy Notice accessible throughout the R360 Platform. You should review this privacy notice periodically. The “Date of Last Revision” included at the beginning of this privacy notice will indicate when it was last updated.

 

By continuing to access or use our R360 Platform, you are confirming you have read and understand the latest version of this Privacy Notice.

Contacting Us 

If you have any questions regarding this Privacy Notice or our associated information practices, you may contact our Privacy Officer and the privacy team as follows:

  • Send us an e-mail at: support@record360.com, or
  • Write to us at: 1333 North California Blvd., Suite 448, Walnut Creek, CA 94596
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