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Privacy Policy

Effective Date
This Privacy Policy was last modified on January 8, 2019.

This website is operated by Ring Limited (“Ring”, “we” or ”us”). 
This Privacy Policy covers how we collect, receive, use, retain, process, disclose, transfer and secure Personal Information on http://www.ringlimited.com (the “Website” or “Site”) and through our online advertising services (“Adverting Services”), which we provide to our partners. It also describes your choices regarding use, access and correction of your Personal Information. Our partners, including clients such as advertisers or publishers, are referred to in this Policy as “Advertising Customers.” All references to “you,” “your” or “user” apply to any person viewing, using or accessing the Site and its features and services, whether or not they are Advertising Customers.

“Personal Information,” also referred to in this Policy as “personal data” or “PII” is information about you that is personally identifying, such as your name, email address, or telephone number, and that is not otherwise publicly available. The definition of Personal Information depends on your physical location and may include other types of information as well, such as location data, your Internet Protocol (IP) address or other unique identifier. Only the definition of Personal Information that applies to your physical location will apply to you under this Privacy Policy. For U.S. users, this Privacy Policy covers information we collect online. For EU users, this Privacy Policy covers information we collect online and offline. For users outside the US and EU, this Privacy Policy covers information we collect online only, unless local law requires otherwise.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Ring participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Ring is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List, here: https://www.privacyshield.gov.

To learn more about the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity & Purpose Limitation, Access and Recourse, Enforcement & Liability, please visit https://www.privacyshield.gov/welcome.

Ring is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Ring complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Ring is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Ring may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted, as described more fully on the Privacy Shield website here: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.

Agreement
By accessing this Site, by becoming an Advertising Customer, and/or by providing Personal Information, you accept and hereby expressly and unambiguously consent to our collection, use, retention, processing, disclosure and transfer, including cross-border disclosure and transfer, of your Personal Information in accordance with the terms of this Privacy Policy.

This Privacy Policy may change from time to time, so please check back periodically to check the most recent modification date to ensure that you are aware of any changes in our processing of your Personal Information. If we make any material changes we will notify you by means of a notice on this Site prior to the change becoming effective. Your continued use of the Site or Advertising Services after any changes signifies your express and unambiguous consent to any such changes. If you do not agree to such changes, you must immediately stop using the Site and Advertising Services.

Information Collection and Use; Choice and Consent 
Users can browse the Site without logging in or providing any Personal Information. Providing Personal Information is necessary to become an Advertising Customer and to access our advertising platform and certain features and services available on the Site. It is always your choice whether or not to provide us with such information. If you do not provide the necessary information you will not be able to become an Advertising Customer and you will not be able to access our ad serving platform or certain services available on the Site. We also will have no way to respond to your questions or inquiries or to provide a demo or other requested services. By using or providing Personal Information to the Site or becoming an Advertising Customer, you are providing your express consent to the collection, use, retention, processing, transfer, and disclosure, including international transfer and disclosure, of your Personal Information as described in this Privacy Policy.

We use your information to provide the services you have requested, such as to receive information about our products and services, to become an Advertising Customer, to process your billings, to be contacted in regards to an employment opportunity or to provide you with customer service. We also use your email address to send you email updates and promotional materials from or about Ring if you are a U.S. resident or if you are an E.U. resident and have opted in to receive promotional emails. You may unsubscribe from promotional emails at any time by clicking “unsubscribe” on the emails you receive from us.

We do not collect Personal Information through the Advertising Services, as all information collected is non-personally-identifiable data.

While we do collect non-PII from third party sources, it is our policy not to supplement any directly personally identifiable data we have with any data from third party sources. For example, we may receive PII such as physical addresses from our data providers, which we de-identify and use for geofencing and to provide analytical reports to our Advertising Customers.

Please note that at some of Ring’s partner or advertiser properties, users may be asked to register and provide personally identifiable data. Although Ring is committed to making sure that our partners provide notice and choice to all consumers, the collection and use of such PII is controlled by the policies found on those sites. Since Ring cannot control those third party sites, we recommend that you take appropriate steps to control the use of PII on third party sites.

You may revoke your consent, and/or object to or block processing of the Personal Information you provide to us by emailing a request to us at [email protected]. We will respond to your request in a reasonable timeframe and in accordance with the law that applies to you. Your Personal Information which we processed prior to your request may not be deleted from our Site system records but will be blocked from further processing without your permission. A request to revoke consent or block processing of your Personal Information may not apply to information collected by cookies or used internally to recognize you and/or facilitate your visits to the Site, or information we may keep to comply with legal requirements.

Non-Personally-Identifiable Information 
Passive Collection
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

Tracking Technologies
Our third party vendors and we use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. In addition, we use persistent cookies to assist us with the collection and use of non-personally-identifiable browsing data, including IP address and Cookie ID for online behavioral advertising (“OBA”) activities. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. We do not link the information we store in cross-site advertising cookies to any personally identifiable information you submit while on a site. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still navigate Websites, but your ability to use some areas of the site may be limited.

Local Storage
Our third party vendors may also use Local Storage/HTML5 to collect and store information in order to provide certain features on our website or to display advertising based upon your web browsing activity. Various browsers may offer their own management tools for removing HTML5.

Clear Gifs (Web Beacons/Web Bugs) 
We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage the advertising content on our network of third-party sites. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to personally identifiable information.

In performing our Advertising Services, we collect non-personally identifiable consumer information in multiple ways, including:

  • on our own web sites
  • on the web sites of publishers or Advertising Customers that call our pixels (or “beacons”)
  • when we serve online advertisements, and
  • from third party providers

This non-personally-identifiable data includes, but is not limited to, information such as a web visitor’s web pages which have been viewed by a web visitor, date and time, IP address, Cookie IDs, domain type, and responses by a web visitor to an advertisement delivered by us or a third party advertising technology vendor. As the Internet evolves, we may use different types of technologies to collect these types of non-personally-identifiable data. The collection of this non-personally-identifiable data allows us and our advertisers to better target advertising to user interests. The data also allows us provide improvements to our services, for example, improving the effectiveness of the advertisements delivered to users and limiting the number of times a person sees a given advertisement.

JavaScript 
We also use JavaScript to assist us with the collection and use of de-identified browsing data, including IP address and Cookie ID.

Data Retention 
We will retain the information you provide to the Site for as long as your account is active, as needed to provide you services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We retain the information we collect through our Advertising Services for 30 days.

Security
Ring uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information and to protect it against loss or unauthorized use or disclosure. As the Internet is not 100% secure, we cannot, however, ensure or warrant the security of any information you transmit to Ring and you do so at your own risk. Once we receive your transmission of information, Ring makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Information Sharing and Disclosure 
We will not sell, trade or share your Personal Information with other companies for their direct marketing purposes.

We share your Personal Information with our third party vendors who provide services on our behalf, such as an email marketing company who distributes our newsletters to our users, and our third party payment processors who process your transactions. These companies are authorized to use your Personal Information only as necessary to provide these services to us.

Information that we collect through our Advertising Services is shared with and disclosed to our Advertising Customers to enable them to serve targeted advertisements to user devices based on the user’s browsing history and online activities. As stated above, only de-identified, Non-Personal Information is collected by the Advertising Services.

Ring may also disclose any information if required to do so by law or in the good faith belief that such action is necessary to: (1) conform to the edicts of the law or comply with legal process served on Ring, (2) protect and defend the rights or property of Ring; (3) act in urgent circumstances to protect the personal safety of users of Ring, its websites or the public; (4) to provide updates and services that may be of interest to the customer; or (5) prevent online fraud or other cyber threats, for example through an online threat exchange, or to report, detect and/or prevent security events.

Ring is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In the events above, you will be notified via email of such disclosure, as well as any choices you may have regarding your personal information, in accordance with applicable law.

Sale of Assets 
In the event that another company acquires all or substantially all of the assets related to the business, we reserve the right to include, disclose and transfer any or all stored Non-Personal and Personal Information among the assets transferred to the acquiring company. If Ring is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

International or Cross-Border Transfer of Your Personal Information and Your Express Agreement 

Given that the Internet operates in a global environment and that transfer of your data is necessary to provide you with requested services, to provide updates, to respond to your inquiries, and to provide Advertising Services, using the Internet to collect and process Personal Information necessarily involves the transmission of data on an international, or cross-border, basis. By providing Personal Information and/or by communicating with us by email, you acknowledge and expressly consent to our processing and disclosure of your Personal Information in this way. The Personal Information of users who are located outside the U.S. may be transferred outside of each eligible country to the U.S., where our servers are located and where it will be processed and stored on servers in the U.S.  By accessing the Site, using Advertising Services, providing Personal Information or sending us email, you expressly and unambiguously agree to such transfer, processing, storage and disclosure in countries outside the EU. 

Links to Other Sites; Transactions with Third Parties 
The Site may contain links to other sites that are not owned or controlled by Ring. Please be aware that we are not responsible for the privacy practices of these other sites. We encourage you to review the privacy policies and statements of other sites to understand their information practices. Our Privacy Policy applies only to information collected by our Site.

The Site uses Google Analytics. For more information about Google analytic cookies, please see Google’s help pages and privacy policy: Google Privacy Policy: http://www.google.com/intl/en/policies/privacy/ 
Google Analytics Help: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage Google has developed the Google Analytics opt-out browser add-on for the Google Analytics JavaScript (ga.js, analytics.js, dc.js). If you want to opt out of Google Analytics, you can download and install the add-on for your web browser at https://tools.google.com/dlpage/gaoptout.

Third Party Advertising 
We partner with a third party to either display advertising on our Website or to manage our advertising on other sites. Our third party advertising vendor may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here http://preferences-mgr.truste.com/, or if located in the European Union click http://www.youronlinechoices.eu/. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Children’s Privacy
Our Site is not directed to children and we do not knowingly collect Personal Information from users who are under age 13. If you believe your child has provided Personal Information to the Site, please contact us at [email protected] 

Accessing Your Information 
You may access your Personal Information that we hold, as well as to correct, amend or delete information that is inaccurate by contacting us at [email protected] . In addition, upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at [email protected] . We will respond to these requests in accordance with the laws that apply to you and within a reasonable timeframe. You can help us maintain the accuracy of your information by notifying us of any changes to your information.

Advertising Services; Collecting Information on Users’ Online Activities Across Devices Over Time 
Ring provides its online Advertising Services to Advertising Customers through site retargeting, search retargeting, contextual retargeting, Facebook API and the collection of location data (“GeoFencing”) of Internet users. These services are provided through third party websites owned and operated by our Advertising Customers who publish their own content on the Internet. We may receive PII such as physical addresses from our Advertising Customers, which we de-identify and use for GeoFencing and to provide analytical reports to our Advertising Customers.

Through our Advertising Services, we collect Personal Information and Non-Personal Information regarding users’ online activities over time and across non-affiliated web sites, mobile applications, or online services, as applicable, and across multiple devices. We collect this information for the purposes of predicting user preferences or interests so our Ad Serving Customers can deliver advertising to a user’s computer or device based on the preferences or interests inferred from his/her online activities.

In some cases Ring may receive Precise Location Data (as defined by the NAI) when, for example, a user makes such information available through a third party mobile application or webpage on a particular device.

Ring engages in cross-device linking for the purposes of serving interest-based advertising. This data is collected and provided to us through a third party.

Advertising Opt-Out Rights — To Stop Receiving Online Behavioral Advertising From Us.
Users may opt out of Ring’s Advertising Services at http://optout.networkadvertising.org. If you opt-out, we will still collect and store information for metrics and analytics purposes and we may still serve you advertising, but not based on such information. Opting-out for one of your devices will not serve as an opt-out for all of your devices. If you wish to opt-out for all of your devices, you must opt-out for each one. In the case that Ring has identified multiple devices as belonging to a single user, as in the case of cross device mapping. We no longer use data from the opted out device for targeted advertisements, nor use data collected on other devices to inform advertisements on that device.

You can learn more about, and opt out of, online advertising on the Network Advertising Initiative’s Consumer Opt-Out page at: http://www.networkadvertising.org/choices/#completed. In addition, you can opt out of certain online advertising at https://preferences-mgr.truste.com.

Mobile Advertising IDs and Opting Out from Advertising 
Most devices come with an identifier for advertising purposes that allows advertisers to track and identify users’ consumer interests, and which also provide an opt out.

For iOS:Every iOS device comes with an identifier for advertising (IDFA), which has two key features:

  • It can be reset by the user at any time.
  • Users can opt out of all remarketing by enabling a device setting called “Limit Ad Tracking” (LAT), which restricts advertisers from using the IDFA for behavioral advertising. Learn how here: https://support.apple.com/en-us/HT202074

For Android:Every Android device comes with an Android Advertising ID. To opt out or change your Advertising ID settings, follow these instructions.

1. If you run Android 2.3 or above, go to your Apps drawer and find ‘Google Settings’.
2. Select Ads.
3. Tap ‘Reset advertising ID’ to get a new ID number, which will also delete any previous information stored.
4. Then check the ‘Opt out of interest-based ads’ checkbox.

If you prefer, you can instead view and modify your current ad settings through web interface by clicking on ‘Ads Settings’.

NAI Mobile Opt-Out Page and Limit Ad Tracking: You can find opt-out settings for various mobile devices at http://www.networkadvertising.org/mobile-choices.

Contact Us About Complaints, Questions, Comments, or Notices relating to this Privacy Policy
Ring commits to resolving requests or complaints about your privacy and our collection, use or transfer of your Personal Information. Users with a need to provide a Notice to us under this Policy or our Terms of Use, or Users with inquiries or complaints regarding this Privacy Policy should first contact Ring at:

[email protected] 

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