Privacy Policy

Last Updated: 1/12/2024

This Privacy Notice ("Notice") provides additional specific information for "Consumers" as defined in the California Consumer Privacy Act of 2018 ("CCPA") and the California Privacy Rights Act ("CPRA"). This Notice is a supplement to other privacy policies or notices issued by Riverbend, Inc ("Company", "We", "Us", or "Our"). In the event of a conflict between any other Riverbend, Inc policy, statement, or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA and CPRA.

In accordance with the CCPA's and CPRA's requirements, this Notice describes our collection, use, disclosure of California Consumers' "Personal Information" or "PI" as defined by the CCPA and CPRA, as well as the rights California Consumers have under the CCPA and CPRA. Terms defined in the CCPA and CPRA that are used in this Notice have the same meanings as the CCPA and CPRA.

The following rights are also available to residents of the following states:

• The Right to Opt Out of Certain Processing: Colorado, Connecticut, Virginia
• The Right to Opt In for Sensitive Data Processing: Colorado, Connecticut, Virginia
• The Right Against Automated Decision Making: Colorado, Connecticut, Virginia

Disclosure of Personal Information, No Sale:

Riverbend has not sold Personal Information (as defined or as contemplated by the CCPA or CPRA) in the preceding twelve (12) months. As defined and contemplated by the CCPA and CPRA, Riverbend does not sell Personal Information of minors under the age of sixteen (16).

California Consumer Privacy Rights

As a California Consumer, you have the following rights:

• Right to Disclosure: California Consumers have a right to request information from us regarding the Personal Information we collect and disclose for business purposes about you, the consumer.
• Right to Deletion: In certain circumstances, you have the right to request we delete Personal Information we collected from you.
• Right to Non-Discrimination: Riverbend will not discriminate against California Consumers for exercising their rights under the CCPA or CPRA.
• The Right to Opt-Out of the Sharing of Your Personal Information
• The Right to Correct Inaccurate Personal Information
• The Right to Limit Use and Disclosure of Sensitive Personal Information
• The Right Against Automated Decision Making

Collection and Use of Personal Information

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information").

The following is a description of our data collection practices, including the personal data we may collect, the source of that information, the purposes for which we collect information (in addition to as otherwise set forth herein), and whether we disclose that information to external parties. We may use any and all of the information for any purposes described in this Privacy Notice. We may not collect additional categories of personal information or use personal information collected for additional purposes that are incompatible with the disclosed purposes for which the personal information was collected, without providing consumers with notice.

Our collection, use, retention, and sharing of a consumer's personal information shall be necessary and proportionate to achieve the purposes for which such information is collected or processed, or for another disclosed purpose that is compatible with the context in which the personal information was collected, and not further processed in a manner that is incompatible with those purposes.

We may not retain a consumer's personal information or sensitive personal information for each disclosed purpose for which the personal information was collected for longer than is reasonably necessary for that disclosed purpose.

We collect personal information directly from you, from your browser or device when you visit our websites, from third parties that you permit to share your information or from third parties that share public information about you, as stated above.

See the section above, "How We Use Personal Information," to understand how we use the personal information collected from California consumers.

Below is a list of categories of personal information and a discussion as to whether we have collected any such information within the past twelve (12) months:

PERSONAL IDENTIFIERS

• We collect your name, address, email address, zip code, telephone number, date of birth, phone number, and other similar personal identifiers when you create an account with us or it is provided to us. We use this information to provide our Services, as well as to respond to your requests.
• We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity, and measure the effectiveness of online services, applications, and tools.
• We collect your Device ID automatically when you use our Services. We use this information to monitor your use and in furtherance of providing our Services to you.
• Other personal information, such as personal information you provide to us in relation to a survey, comment, question, request, article download or inquiry and any other information you upload to our application.

CUSTOMER RECORDS INFORMATION AND PERSONAL DATA PROTECTED AGAINST SECURITY BREACHES (CAL. CIV. CODE 1798.80(E))

• We collect your name, phone number, username, password, company name, job title, business email address, and department when you create an account with us or provided to us. We use this information to provide our Services and to respond to your requests.
• We may collect banking information in order to provide the Services.
• We collect life or health insurance or other financial services information directly from you or from records provided to us. We may use this information to provide you with the Services.

PROTECTED CLASSIFIED INFORMATION

• We do not collect protected classified information.

COMMERCIAL INFORMATION

• When you engage with us, we create records of your interactions with us and the Services provided. We use this information to measure the effectiveness of our Services and use this information to better calibrate our assessment tool.

BIOMETRIC INFORMATION

• We do not collect any biometric information about you.

INTERNET OR OTHER SIMILAR NETWORK ACTIVITY

• We collect information regarding your interaction with our Website. This includes device(s) used to access the services and information regarding your interaction with our Website or Services and other usage data.

GEOLOCATION

• As described above, we collect your IP address automatically when you use our Site. We can determine your general location based on the IP address, but not your precise geolocation.  Riverbend does not collect data related to your precise geolocation.

AUDIO/VIDEO DATA

• If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We may collect sensory information, the content, audio and video recordings of conference calls between you and us that we record where permitted by you and/or the law. We do not collect thermal, olfactory, or similar information.

PROFESSIONAL OR EMPLOYMENT RELATED INFORMATION

• We collect business information, including your name, company, and job title, and business contact details from you. We use this information to reach out to you in furtherance of the provision of our Services.

EDUCATION INFORMATION

• We do not collect any information about the institutions you have attended.

SENSITIVE PERSONAL INFORMATION (See Below)

Sharing your Data and the Recipients of your Personal Information

We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors, (ii) strategic partners; and (iii) analytics providers.

When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except in performance of the contract.  The CCPA and CPRA prohibit third parties who receive the personal information we hold from selling it unless you have received explicit notice and an opportunity to opt-out of such downstream sales.

Either we or our Service Providers may use your information for the following Business Purposes (as defined in the CCPA and CPRA) on a day-to-day basis:

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer's experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
• Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Do We Sell or Share Your Personal Information?

As mentioned above, we do not sell your personal information as currently defined under the CCPA and as amended by the CPRA, meaning that we do not rent, disclose, release, transfer, make available or otherwise communicate your personal information to a third party for monetary or other consideration. We will not sell your information unless we modify this Privacy Policy and take the additional steps required under the CCPA.

While we do not sell Personal Information for monetary value, we may share it with a third party or disclose it to a service provider or contractor in furtherance of a business purpose.  In accordance with the CPRA, you have the right to opt-out of Riverbend sharing or otherwise disclosing your personal data. If you choose to opt-out of Riverbend sharing your data, you can do so by emailing us at privacy@riverbendindustries.com.

If we do share your Personal Information with a third party, Riverbend shall enter into an agreement with such third party, service provider, or contractor that: (1) specifies that the personal information is disclosed by Riverbend only for limited and specified purposes; (2) obligates the third party, service provider, or contractor to comply with applicable obligations under the CPRA and obligate those persons to provide the same level of privacy protection as required by the CPRA; (3) grants Riverbend rights to take reasonable and appropriate steps to help ensure that the third party, service provider, or contractor uses the personal information transferred in a manner consistent with the Riverbend' obligations under the CPRA; (4) requires the third party, service provider, or contractor to notify us if it makes a determination that it can no longer meet its obligations under the CPRA; and (5) grants Riverbend the right, upon notice, including under (4), to take reasonable and appropriate steps to stop and remediate unauthorized use of Personal Information.

Under the right to delete provisions of the CPRA, Riverbend will enter into an agreement with a third party that (1) the service provider or contractor shall cooperate with the Company in responding to a verifiable consumer request; and (2) that at the direction of Riverbend, shall delete, or enable Riverbend to delete, and shall notify any of its own service providers or contractors to delete, personal information about the consumer collected, used, processed, or retained by the service provider or the contractor.

Additionally, the service provider or contractor shall notify any service providers, contractors, or third parties who may have accessed personal information (requested for deletion) from or through the service provider or contractor, unless the information was accessed at the direction of Riverbend, to delete the consumer's personal information, unless doing so proves impossible.  A service provider or contractor shall not be required to comply with a deletion request submitted by the consumer directly to the service provider or contractor to the extent that the service provider or contractor has collected, used, processed, or retained the consumer's personal information in its role as service provider or contractor to Riverbend.

How Long Do We Keep Your Data?

For each of the categories of personal data and for the sensitive personal data, below please find information regarding how long we keep such data or how we will decide to dispose of such data.

• Personal Identifiers:
  • We collect this data as provided by you to us, and we utilize this data in furtherance of providing Services to you. We keep this data for as long as it's needed to provide Services to you, or as may be required under applicable law and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.

• Customer Records Information:
  • We collect this data when you create an account with us and use it to provide Services to you. We keep this data for as long as it's needed to provide Services to you, or as may be required under applicable law and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.
• Protected Classified Information Under California Law:
  • We collect information about you, including your age and date of birth, when you create an account with us or if you provide this information to us. We keep this data for as long as it's needed to provide Services to you, or as may be required under applicable law and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes
• Commercial information:
  • When you create an account or otherwise engage with us via our Website or app, we create records of your interactions with us and the Services provided. We utilize this information to measure the effectiveness of our Services. We keep the data for as long as it's needed to provide Services to you, or as may be required under applicable law, and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.
• Biometric Information:
  • Riverbend does not collect any biometric data.
• Internet and other electronic network activity:
  • We collect information regarding your interaction with our Website. This includes device(s) used to access the Website and information regarding your interaction with our Website or in the provision of our Services to you. We keep this data for as long as it's needed to provide Services to you, or as may be required under applicable law, and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.
• Geolocation Data:
  • As described above, we collect your IP address automatically when you use our Site. We can determine your general location based on the IP address, but we do not and cannot determine your precise geolocation. We keep this data until we determined that it is no longer needed to achieve our business-related purposes, or as may be required under applicable law, and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.
• Audio, electronic, visual, thermal, olfactory, or similar information:
  • If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of such call.  We may collect the content, audio, and video recordings of conference calls between you and us that we record where permitted by you and/or by law.  We keep this data for as long as it's needed to provide Services to you, or as may be required under applicable law, and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.  We do not collect thermal, olfactory, or other similar information.
• Professional or employment-related information:
  • We collect business information, including your name, company, job title, and business contact details from you which you provide to us. We use this information in furtherance of our Services.  We keep this data for as long as it's needed to provide Services to you, or as may be required under applicable law, and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.
• Sensitive Personal Information (See Below).

Do We Use your Data for Automated Decision Making?

            We do not use your data for automated decision making (i.e. data profiling) purposes.

How to Exercise Your Rights Under the CCPA/CPRA

Under the CCPA and CPRA you have the right to find out about the personal information that we have collected and how that information has been used or disclosed. You also have the right to request that we delete or correct your personal information (and/or opt-out of the sale or sharing of your personal information).

If you wish to exercise any of these opt-out rights, or if you would like additional information, please contact us at the following email address: privacy@riverbendindustries.com, or call us at the following toll-free number: (888) 700-0096.

1. The Right to Access and Know About Personal Information Collected, Disclosed, or Shared

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties to whom we disclose that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, identifying the personal information categories that each category of recipient obtained.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

2. The Right to Request Deletion of Your Personal Information by Riverbend and Third Parties

Subject to certain exceptions, you have the right to request that we delete any of all of your personal information that we collected from you and retained over the past twelve (12) months. Please bear in mind that deletion of your personal information may not allow Riverbend to continue to provide the Services to you.  Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers or contractors to delete) your personal information from our records, unless an exception applies. Additionally, upon receiving a verifiable consumer request, we will notify all third parties to whom Riverbend Inc. has shared such personal information to delete the consumer's personal information, unless doing so is proven to be impossible or involves disproportionate effort.  You may request that only a portion of your information be deleted.

We may deny all or part of your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated based on our ongoing business relationship with you, or otherwise perform our agreement with you
• Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes.
• Debug products to identify and repair errors that impair existing intended functionality
• Exercise free speech or ensure the right of another consumer to exercise their right of free speech or other right provided for by law
• Engage in public or peer reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business's deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent
• To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer's relationship with the business and compatible with the context in which the consumer provided the information
• Comply with a law or a legal obligation

Riverbend Inc. may maintain a confidential record of deletion requests solely for the purpose of preventing the personal information of a consumer who has submitted a deletion request from being sold, for compliance with other laws, or for other purposes solely to the extent permissible under the CPRA.

3. The Right to Opt-Out of the Sharing of Your Personal Information

"DO NOT SELL OR SHARE MY INFORMATION"

The CCPA and CPRA provide you with the right to opt out and stop businesses from selling or sharing your personal information.  This right applies to all California consumers ages 16 or older and may be exercised at any time.

The right to opt out of sharing personal information includes sharing with a third party even when there is no exchange of consideration between the parties. This can include the right to opt out of Riverbend Inc. using technologies like cookies and pixels to track you across other websites, apps, or services that then share that information with ad networks to deliver targeted advertisements to you.

If you are 16 years of age or older, you have the right to direct us to not share your personal information at any time (the "right to opt-out"). Our websites and products are not intended for minors. We do not sell or share the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization to sell or share (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sharing may opt-out of future sharing at any time.

How to exercise this right:

• By contacting Riverbend Inc. at the toll free number: (888) 700-0096; or
• By sending an email to the following address: privacy@riverbendindustries.com, providing specific details of your request

Do Not Track. We do not track our customers over time and across third party websites to provide targeted advertising and, therefore do not respond to Do Not Track (DNT) signals. 

4. The Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA or CPRA rights, and will not engage in the following behaviors:

• Denying you goods or services
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
• Providing you a different level or quality of goods or services
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
• Retaliating against an employee, applicant for employment, or independent contractor as defined under the CPRA, for exercising their rights under the CPRA.

When you exercise these rights and submit a request to us, we will verify your identity by asking for information about your relationship with Riverbend Inc., such as an email address on file or other methods of verification as allowed under the CCPA and CPRA.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

5. The Right to Correct Inaccurate Personal Information

You shall have the right to request that we correct any inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. If Riverbend Inc. collects your personal information we shall disclose, pursuant to the CPRA, section 1798.130, your right to request correction of inaccurate personal information, which you may do by contacting us at the following email address: privacy@riverbendindustries.com. Or by calling us at the following toll-free number: (888) 700-0096.

If Riverbend Inc. receives a verifiable consumer request to correct inaccurate personal information, we shall use commercially reasonable efforts to correct the inaccurate personal information, as directed by you pursuant to your rights under the CPRA. We shall also ask any third parties and service providers to whom information has been shared with to correct or delete your personal information upon your request.

6. The Right to Limit Use and Disclosure of Sensitive Personal Information

For purposes of the CPRA, sensitive personal information ("SPI") includes the following personal information:

• Any communications that you have with a third-party.
  • Riverbend does not collect any data related to communications you have with a third-party
• Biometric data processed to identity an individual
  • Riverbend does not collect any biometric data
• Data about sexual orientation or sex life
  • Riverbend does not collect any information regarding sexual orientation or sex life.
• Financial account details in a combination (e.g. card number and password) that gives or provides access to an account.
  • Riverbend does not collect any of this data related to financial accounts.
• Genetic data
  • Riverbend does not collect any genetic data
• Government-issued numbers (such as a social security number or a number on a passport, or driver's license number).
  • Yes, Riverbend does collect driver's license numbers and passport numbers in certain circumstances. Riverbend also collects SSNs via employer contribution files (Riverbend' internal systems utilize alternate IDs in place of SSNs for use in any data transfers).
• Health Data
  • Riverbend does not collect any health data.
• Philosophical or religious beliefs
  • Riverbend does not collect any information related to philosophical beliefs.
• Precise geolocation
  • Riverbend does not collect any data related to precise geolocation.
• Racial or ethnic origin
  • Riverbend does not collect any data or information related to racial or ethnic origin
• Union membership
  • Riverbend does collect information about union membership. We keep this data for as long as it's needed to provide Services to you, or as may be required under applicable law, and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.

Please note that any information that is already publicly available shall not be considered SPI or personal information.

With regard to any of the data from the above-listed categories which Riverbend does collect, Riverbend utilizes the data in furtherance of providing Services to you, and will keep the data for as long as it's needed to provide Services to you, or as may be required under applicable law, and we will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.

Our use and disclosure of your SPI is limited to those uses which are necessary to perform the Services reasonably expected by an average consumer who requests such Services, including the following Services:

• to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for security and integrity
• To debug to identify and repair errors that impair existing intended functionality
• To perform services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured for, or controlled by Riverbend Inc., and to improve, upgrade, or enhance the service or device that is owned, manufactured for or controlled by Riverbend Inc.

Riverbend only uses SPI to provide the Services.  As such, the use of your SPI is already limited to uses in furtherance of the provision of our Services to you, as we do not use it for other non-Services related purposes.  As such, since use of your SPI is already limited to the provision of the Services to you and not used for any other purpose, your right to limit the use of your SPI to the provision of Services is already attained and exercised.

7. Right Against Automated Decision Making