Privacy Policy - RPM Living

RPM Living Privacy Policy

Last Updated: [06/20/2024]

RPM Living (“RPM,” “we,” “us,” or “our”), is an innovative, full-service multifamily property management, investment, and development company. This Privacy Policy is designed to help you understand how we collect, use, process, and share information that identifies you (your “personal information”), and to help you understand and exercise your privacy rights.

SCOPE AND UPDATES TO THIS PRIVACY POLICY
PERSONAL INFORMATION WE COLLECT
HOW WE USE YOUR PERSONAL INFORMATION
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
YOUR PRIVACY CHOICES AND RIGHTS
SECURITY OF YOUR INFORMATION
INTERNATIONAL DATA TRANSFERS
RETENTION OF PERSONAL INFORMATION
NOTICE AT COLLECTION AND SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS AND RESIDENTS OF CERTAIN OTHER STATES
CHILDREN’S INFORMATION
OTHER PROVISIONS
CONTACT US

1. SCOPE AND UPDATES TO THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively called the “Services.”

We also provide commercial property management and other services to other businesses and enterprises (our “customers”). This Privacy Policy does not apply to personal information that we process on behalf of our customers (“Customer Data”). Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. Our customers’ respective privacy policies and contractual terms with you or others govern their collection and use of Customer Data.

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated terms of this Privacy Policy if you continue to use our Services after a new Privacy Policy takes effect.

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. For residents of certain states, additional disclosures about the information we collect is available in our supplemental disclosure below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

Account Creation. We may collect personal information when you create an account, such as name, email address, telephone number, and any other details in connection with your account.
Rental Application. We collect personal information when you apply to rent an apartment, such as a background check, references, proof of identification, bank statements, pay stubs, and any other details provided on your application.
Payments. We may collect personal information and details associated with any payments you make. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.
Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications and Recruiting. If you apply for a job with any of our companies, we may collect information that will be used to assess your skills, qualifications, and interests to determine alignment with career opportunities with us or our affiliates and to communicate with you regarding the status of your application.  If you are offered and you accept a position with one of our organizations, your application data may become part of your worker file. Details about how we handle your personal information as an applicant or worker are provided in our Applicant and Worker Privacy Notice, not this Privacy Policy.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use our Services.

Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

Location Information. We may collect precise location information, such as if you use our App or other aspects of our Services to communicate with us (for example, to submit a work order for maintenance or other request related to your residential unit) or manage your relationship with us.

Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
Advertising or Targeting-Related. We may use first party or third-party Technologies[, including cross-device tracking,] to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties.
Some of the advertising Technologies we use include:

Google Advertising. For more information about Google’s use of your personal information, please visit Google’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. [To the extent these are used, include: Some of our analytics partners include:

Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

Social Media Platforms. Our Services may contain social media buttons, such as Facebook, LinkedIn, and Instagram, which might include widgets such as the “share this” button or other interactive mini programs). These features may collect personal information such as your IP address and which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

B. Personal Information Collected from Other Sources

Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.

Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your information to fulfil our contract with you and provide you with our Services, such as:

Managing your information and accounts;

Evaluating your application for residency;
Providing access to certain areas, functionalities, and features of our Services;
Answering requests for customer or technical support;
Communicating with you about your account, activities on our Services, and policy changes;
Processing your financial information and other payment methods for products or Services purchased; and
Allowing you to register for events.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Services;
Short-term, transient use, such as contextual customization of ads;
Improving, upgrading, or enhancing our Services;
Developing new products and services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
Debugging to identify and repair errors with our Services;
Auditing relating to interactions, transactions, and other compliance activities;
Sharing personal information with third parties as needed to provide the Services;
Enforcing our agreements and policies; and

Carrying out activities that are required to comply with our legal obligations.
We may use your information for other legitimate business purposes as permitted by law.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, text messages, custom audiences advertising , and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create.

3. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Provide our Services

The categories of third parties with whom we may share your personal information are described below.

Service Providers. We may disclose your personal information with our third-party service providers and vendors that assist us with the provision of our Services. Service providers include, for example, internet service providers, data analytics providers, operating systems and providers, and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.
Business Partners. We may disclose your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
Affiliates. We may disclose your personal information with our company affiliates for example: for our administrative purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.
Government Entities. We may disclose your personal information with government entities for example: for our administrative purposes, meet our statutory or regulatory obligations, or in response to any requests.
Social Networks. We may disclose your personal information with our social networks for example: for our advertising purposes and with your permission.

Advertising Partners. Through our Services, we may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “cross-context behavioral advertising,” or “personalized advertising.”
APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

We may also share your information with third parties as appropriate and permitted by law. The privacy choices you may have about your personal information are determined by applicable law and are described in Section 5 below.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).
Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.
Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
Phone calls. If you receive an unwanted phone call from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call or by otherwise contacting us as set forth in “Contact Us” below.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Personalized Advertising. You can control our use of certain cookies and Technologies in the following ways:
Website Cookie Controls. When you first visit our website, you will be presented with a banner that informs you about the categories of cookies and other tracking technologies (“Technologies”) used on that site and your options for controlling those technologies based on the jurisdiction applicable to your use of the website. Where applicable, you will have a choice about whether to accept or opt-out of certain cookies and technologies, the use of which may constitute a “sale” or “share” of personal information under applicable law and may be used for targeted advertising. Please note that cookies are browser and device specific. Your request to opt-out or reject the use of these Technologies will be linked to your browser identifier only. If you use a different computer, mobile device, or Internet browser to access our sites, you will need to renew your cookie management choices. Where available, you can do so by clicking on the cookie icon that appears when you return to our Services or the [“Your Privacy Choices” link] at any time to manage your preferences.
Browser and Device Controls. You may also stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. These tools are generally available in the help section of browsers. You can also use the quick links, based on the browser type that you are using: Internet Explorer, Google Chrome, Firefox, and Safari. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.
Global Privacy Control. You may exercise your opt-out right by broadcasting an opt-out preference signal, called the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). You can learn more about the Global Privacy Control here. Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access our sites, you will need to renew your opt-out request.
Ad Industry Opt-outs. In addition, the online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Access and Portability of your personal information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format;
Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
Request Deletion of your personal information;
Request Restriction of or Object to our processing of your personal information where the processing of your personal information: (i) is based on our legitimate interest for direct marketing purposes; (ii) involves processing or sharing of your sensitive personal information for certain non-essential purposes, or in contexts that require your consent; and (iii) for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
Opt-out of Sale, Sharing for Cross-Contextual Advertising, or Targeted Advertising involving your personal information. Although we do not “sell” your personal information as the term “sale” is typically understood, we may share your information with analytics providers and advertising networks in order to understand how visitors use our websites and serve you ads on and off our websites. You may opt-out of this “sharing” and “targeting advertising” by adjusting your privacy choices. When you first visit our website, you will be presented with a banner that informs you about the categories of cookies and other tracking Technologies used on that site and your options for controlling those technologies based on the jurisdiction applicable to your use of the website. Where applicable, you will have a choice about whether to accept or opt-out of certain cookies and technologies, the use of which may constitute a “sale” or “share” of personal information under applicable law and may be used for targeted advertising. Please note that cookies are browser and device specific. Your request to opt-out or reject the use of these Technologies will be linked to your browser identifier only. If you use a different computer, mobile device, or Internet browser to access our sites, you will need to renew your cookie management choices. Where available, you can do so by clicking on the cookie icon that appears when you return to our Services or the “Your Privacy Choices” link at any time to manage your preferences; and
Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws. Residents of certain states have the right not to receive discriminatory or retaliatory treatment by us for the exercise of their rights conferred by applicable law.

6. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

7. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

8. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data. Additionally, we endeavor to retain all such personal information in accordance with legal requirements.

9. NOTICE AT COLLECTION AND SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS AND RESIDENTS OF CERTAIN OTHER STATES

This Notice at Collection and Supplemental Notice is for residents of states that have adopted comprehensive privacy legislation and others that may come into effect from time to time covering personal information collected in a business or employment context, including, but not limited to, California (collectively, “Applicable State Laws”).

The following table describes the categories of personal information RPM has collected and whether RPM disclosed that personal information for a business purpose (e.g., to a service provider). The personal information we collect shall be retained as set forth in “Retention of Personal Information” above.

Category of Personal Information Collected by RPM

Category of Third Parties Personal Information is Disclosed to for a Business Purpose

Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.

Service providers
Business partners
Service providers
Advertising networks
Internet service providers
Data analytics providers
Government entities
Operating systems and platforms
Social networks

Personal information categories

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.

Service providers
Business partners
Affiliates
Data analytics providers
Government entities

Protected classification characteristics under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Service providers
Government entities
Affiliates

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Service providers
Affiliates
Business partners
Government entities

Internet or other electronic network activity

Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.

Service providers
Affiliates
Business partners

Geolocation data

Physical location or movements.

Service providers
Affiliates
Business partners

Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

Service providers
Affiliates
Business partners

Professional or employment-related information

Current or past job history or performance evaluations.

Service providers
Affiliates
Business partners

Inferences drawn from other personal information to create a profile about a consumer

Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Service providers
Affiliates
Business partners

Sensitive personal information

Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credential allowing access to an account; precise geolocation; racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; or genetic data.

Service providers

Sources of Personal Information We Collect

As more fully described in the section titled Personal Information We Collect, the sources from which we collect personal information include directly from you when you interact with us, automatically from you when you use our sites and services (for example through cookies and other online technologies), from third parties (for example, from government agencies) and through referrals from others.

Purposes for which We May Use the Information We Collect

The business purposes for which we collect personal information are described in more detail in the section titled, How We Use Your Personal Information, and include:

To provide our Services to you;
For our administrative purposes (including security, fraud detection and protection, and improve our Services);
To process your requests, orders, and transactions (including provide customer service to you);
To Advertise and Market our products and Services to you;
With your consent; and,
To comply with law and enforce our rights and the rights of others.

Our full Privacy Policy can be accessed here.

“Sales” of Personal Information and Opting Out of Targeted Advertising.

For purposes of Applicable State Laws, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 18 years of age as the term “sell” is commonly understood. That said, we may share information with third-party advertising partners for the purpose of promoting our Services as described above, such as for cross-context behavioral advertising and targeted advertising. To the extent that such sharing is considered a “sale” or “sharing” or disclosing for targeted advertising under Applicable State Laws, you may limit such sharing by:

Exercising Your Privacy Choices and Rights by following the instructions found above in the section titled, Your Privacy Choices and Rights > Your Privacy Choices > Cookies and Personalized Advertising found here
Opting-Out. Clicking on the “Your Privacy Choices” website link found here
Request Form. Completing our online request form at our request portal.
Contact Us. Contacting us as set forth in “Contact Us” below.
Managing Your Cookie Preferences. Completing the steps as set forth in “Website Cookies” above.

The categories of data we share for cross contextual advertising and targeted advertising include:

Online Identifiers such as IP address, marketing id, device identifiers and characteristics,
Internet or other Electronic Network Activity, such as Browsing and Usage
Information; and,
Inferences about individual preferences, characteristics, and behaviors
Each of these categories may have been shared with advertising networks and data analytics providers for the purpose of providing targeted advertising and marketing.

Processing Sensitive Information.

Under applicable laws, you may have the right to limit the processing and disclosure of sensitive personal information for certain purposes such as profiling or inferring characteristics about you. We do not process sensitive personal information for such purposes.

Exercising your Privacy Rights

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” above for additional instructions.

Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services. If we cannot verify your identity or authority to make a request, we may not be able to fulfill your request.

Once you have provided the required information to us, we will confirm your identity by conducting an electronic search of our internal systems to ensure the information provided by you in your request matches what we have in our systems.

To verify your identity, we may ask that you provide the following information when you submit your request:

Your name
Your home address
Your state of primary residence
Your home phone number
Your email address

Depending on your type of request or the information requested by you, we may require additional information in order to verify your identity and fulfill your request. If we cannot successfully verify your identity, we will inform you of that fact.

We will respond to your request within forty-five (45) days or within the time provided for under Applicable Law. However, in certain circumstances, we may require additional time to process your request, as permitted by applicable law. We will advise you within forty-five (45) days after receiving your request if such an extension is necessary and why it is needed. If we cannot fulfill your request, our response to you will also explain the reason why we cannot fulfill your request.

We do not charge a fee to process or respond to your consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Additional Privacy Rights for Residents of Certain States Including California.

Appeal. You may have the right to appeal our decision or response to your request. To exercise your right to appeal, you can submit an appeal request using the same method used to submit your original request, including by contacting us as set forth in “Contact Us” below.

California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in “Contact Us” below.

Financial Incentives

Refer-a-Friend and Similar Incentive Programs. As described above in “How We Use Your Personal Information” (“Share Content with Friends or Colleagues”), we may offer referral programs or other incentivized data collection programs. For example, we may offer incentives to you such as discounts or promotional items or credit in connection with these programs, wherein you provide your personal information in exchange for a reward or provide personal information regarding your friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your data to us depends on how you ultimately use our Services, whereas the value of the referred party’s data to us depends on whether the referred party ultimately uses our Services. Said value will be reflected in the incentive offered in connection with each program.

10. CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.

Protecting children’s privacy online is very important to us. If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, and wish to have that information modified or deleted, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.

11. OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

12. CONTACT US

RPM is the controller of the personal information we process under this Privacy Policy.

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

RPM Living

Privacy Officer

5508 Parkcrest Drive, Suite 320

Austin, TX 78731

privacyrights@rpmliving.com