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Privacy Policy

Last updated: October 8, 2024

Rational 360, Inc. (“Company”, “we”, “our”, or “us”) understands that privacy is important to our users. This Privacy Policy describes our practices regarding the collection, use, sharing, and protection of your personal information for the website located at https://rational360.wpenginepowered.com/ (the “Website”), and any other services provided by us or our affiliates which are not covered by a separate privacy policy (collectively, the “Services”). This Privacy Policy also tells you about the rights and choices you have with respect to your personal information, how you can assert those rights, and how you can contact us to get answers to your questions.

Please note that our privacy practices are subject to the applicable laws of the regions in which we operate. Accordingly, some additional region-specific terms will only apply to individuals in those locations, or as required by applicable laws.

For more information about how users with disabilities can access this Privacy Policy in an alternative format, please contact the Company at (202) 470-4552 or info@rational360.com.

BY USING OR ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES OR PRACTICES, YOU SHOULD NOT USE OR ACCESS THE SERVICES OR PROVIDE US WITH ANY PERSONAL INFORMATION.

The following links will take you directly to the corresponding sections of this Privacy Policy:

    • What Our Privacy Policy Covers

    • Personal Information We Collect from You

    • How We Collect Your Personal Information

    • How We Use Your Personal Information

    • How We Disclose or Share Your Personal Information

    • Links to Other Sites and Social Media Services

    • Interest-based Advertising

    • How We Protect Your Personal Information

    • Data Retention

    • Your Choices

    • Cross-Border Data Transfers

    • Children’s Privacy

    • Changes to This Policy

    • Contacting Us

    • California and Other State Privacy Rights

    • European Privacy Rights

WHAT OUR PRIVACY POLICY COVERS

This Privacy Policy applies to the personal information that we obtain in various contexts, including when you access or use our Services, or communicate with us over email or otherwise via the Services.

PERSONAL INFORMATION WE COLLECT FROM YOU

We use the term “personal information” – also called “personal data” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been deidentified or that otherwise cannot reasonably be related back to a specific person is not considered personal information. The precise definition of personal information may vary depending on your place of residence, but we take the same general approach to protecting your privacy, subject to any additional measures that may be required by applicable laws.

The following are the categories and types of personal information that we may collect from or about you, depending on how you interact with the Services:

HOW WE COLLECT YOUR PERSONAL INFORMATION

Personal Information You Provide

We collect personal information that you provide to us directly. This may include, but is not limited to:

Personal Information We Collect Automatically

When you visit our Services, we or third parties we work with may automatically collect certain information using technologies such as cookies and other tracking technologies described below.

“Cookies” are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, for example, the address of the websites you visited before and after you visited our Services, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Services you visited and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Services. We may also use cookies to customize your visit to the Services and for other purposes to make your visit more convenient or to enable us to enhance the Services. [For additional information about our use of cookies on the Services, please see our Cookie Policy

We may work with third-party vendors who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Services and other Services. One such provider is Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help analyze how users use the Website. The information generated by these cookies about your use (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on activity for its staff, and providing other services relating to web page activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. You may refuse the use of cookies by selecting the appropriate settings in your browser. By using the Website and accepting cookies, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Please refer to the currently available opt-outs for Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.

Our service provider, RevMethods, may place a cookie on your device to collect certain web log data (e.g. IP address, timestamp, page view) when you visit our Website. This data enables RevMethods to predictively identify who is engaging with our digital content. We may use this information to tailor our marketing, communications, and services more effectively, both on this Website and elsewhere. 

If you interact with us on social media, we may collect information that you share with us on social media or that such platforms share with us. Please review the privacy policies and settings of the social media platforms and networks that you use for more information about their privacy practices.

We may obtain information about you from other sources, such as data analytics providers, marketing or advertising vendors, fraud prevention vendors, vendors that provide other services on our behalf, or publicly available sources.

HOW WE USE YOUR PERSONAL INFORMATION

We collect and use personal information for the following purposes:

We reserve the right to supplement your personal information with information we gather from other sources which may include online and offline sources. We may collect information that is not personal information (“non-personal information”), including anonymous or aggregate data, or information lawfully made available from federal, state, or local government records. Because non-personal information does not personally identify you, we may collect, use, and disclose such information for any purpose permitted by law. In some instances, we may combine non-personal Information with personal information. If we combine any non-personal information with personal information, the combined information will be treated by us as personal information to the extent that it is capable of personally identifying you.

HOW WE DISCLOSE OR SHARE YOUR INFORMATION

In addition to using your personal information ourselves for the reasons stated above (and as otherwise mentioned in this Privacy Policy), we may disclose your personal information to other affiliates and entities in the following instances:

We may share your personal information with third-party service providers who may use your information to provide us with services including, but not limited to: website hosting, information technology services, email delivery services, and anti-fraud monitoring. These service providers may have access to personal information that is necessary to perform their functions, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.

We may share personal information with our corporate affiliates and subsidiaries, who process personal information on our behalf, where necessary to provide a service that you have requested, or in other circumstances with your consent or as permitted or required by law.

We may disclose personal information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms and Conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may share your personal information and other information with third parties in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of the Company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the assets transferred may include information about the users of our Services.

We may share non-personal information with unaffiliated third parties, such as business and advertising partners, to improve and enhance your experience using the Services, and for our own market research activities. We publicly commit to maintain and use the information in de-identified or aggregate form, and not to attempt to re-identify the information.  

Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.

We may create links to other websites that we think may be of interest to you, such as providers of various services. We may also provide links that allow you to send or forward a post from our Services through or to third-party social media sites, or other means of electronic communication, such as an email or text messaging service. We do not endorse any other websites, providers, or services by providing such links, and this Privacy Policy applies only to your use of our Services. We are not responsible for the privacy policies of any websites and services we link to on our Services, and you should read the privacy policies of each site you visit to determine what data that site may collect about you.

You should be aware that any personal information which you voluntarily include and transmit online in a publicly accessible blog, forum, social network, or otherwise may be viewed and used by others. By using such features, you assume the risk that the personal information provided by you may be viewed and used by third parties.

INTEREST BASED ADVERTISING

We may ourselves, or with third-party vendors, use your information to deliver targeted advertising to you when you visit our Services or other websites. Cookies, clickstream data, and other similar technologies described below may be used in this process. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising, sometimes called “targeted advertising,” “behavioral advertising,” or “cross-context behavioral advertising,” enables us and our vendors to know about your interests in connection with the delivery of a specific ad. We believe that such advertising is helpful because it allows you to see advertisements that are relevant to your interests.

If you would like to opt out of these interest-based advertisements, please follow the opt-out process described in the section titled Your Choices below.

HOW WE PROTECT YOUR PERSONAL INFORMATION

Personal information is maintained on our servers or those of our vendors, and is accessible by authorized employees, independent contractors, representatives, and agents as necessary for the purposes described in this Privacy Policy. We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal information. However, no method of safeguarding information is completely secure, and we cannot guarantee that our safeguards will be effective or sufficient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us at info@rational360.com.

DATA RETENTION

We will retain your personal information for as long as your inquiry is active or as needed to provide you with the Services, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregate data, or any other data that constitutes non-personal information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

YOUR CHOICES

Consistent with applicable law, you may exercise the choices described in this section regarding your personal information and communications from us. You may also have certain additional rights available depending on laws in your state or country of residence, as described further below in the Privacy Policy.

From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. If you would like to stop receiving marketing or promotional communications via email from us, you may opt out of such communications by clicking on the “UNSUBSCRIBE” button in our email message. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of our Services may no longer be available to you.

If you would like to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our Services or some of its functionality may be affected.

Note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. Additionally, if you opt out on one of your devices, that opt out may not be effective on all of your devices. However, please be advised that cookie-based opt-outs are not effective on some mobile services.

Some browsers have a Do Not Track (“DNT”) feature that lets users signal to websites that they do not want to have their online activities tracked. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. However, if you are a resident of California, we treat opt-out preference signals as a means of opting out of the sale or sharing of personal information, or of opting out of the processing of personal information for targeted advertising, as applicable. Please see the section titled California Privacy Rights below for more information.

You may opt out of receiving targeted ads from certain data and advertising partners that participate in certain industry self-regulatory programs. The DAA provides a website at www.aboutads.info/consumers with information about how to opt out of targeted advertising from some or all of the DAA’s participating companies. Additionally, the Network Advertising Initiative (“NAI”) offers a website at http://optout.networkadvertising.org/ where you can opt out of interest-based advertising from some or all of the NAI’s members. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities.

To learn more from the NAI about how to opt out of targeted advertising on mobile devices, you can also visit the following link: https://thenai.org/opt-out/mobile-opt-out/.

CROSS-BORDER DATA TRANSFERS

If you submit personal information to us, that information may be processed in a jurisdiction where privacy laws may be less stringent than those in your country of residence. By submitting your personal information to us, you agree to the transfer, storage, and processing of such information in foreign jurisdictions including, but not limited to, the United States. Please note that personal information transferred to the United States is subject to access by law enforcement. Where applicable, we may use model clauses approved by the laws of your jurisdiction (such as Standard Contractual Clauses approved by the European Commission) for cross-border data transfers. 

CHILDREN’S PRIVACY

Our Services are intended for users ages 18 and over, and we do not knowingly collect personal information from children under the age of 16. When we become aware that personal information (or other information that is protected under applicable law) from a child under 16 has been collected, we will use all reasonable efforts to delete such information from our databases. If you believe we might have any personal information from or about a child under 16, please contact us by using the information the section below titled Contacting Us.

CHANGES TO THIS POLICY

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time, provided that any such modifications will only be applied prospectively. We encourage you to periodically review the Website for the latest information on our privacy practices. Your continued use of the Services following the posting of any changes to this Privacy Policy means you accept such changes.

CONTACTING US

If you have any questions about our privacy or security practices, you can contact at info@rational360.com, or via the following:

Rational 360

1828 L Street NW Suite 640

Washington, District of Columbia 20036

(202) 470-5337

CALIFORNIA AND OTHER STATE PRIVACY RIGHTS

The California Consumer Privacy Act (“CCPA”) provides you with specific rights regarding your personal information. This section describes the rights that California consumers have and explains how to exercise those rights. To be clear, these rights are granted only to the extent that you are a California consumer and we are acting as a “business” under the CCPA with respect to your personal information. The rights in this section are not intended to grant you additional rights, but only your rights under the CCPA.

Other states may have laws similar to the CCPA.  If such laws apply to you and us, then we will offer you rights similar to those set forth below.

Information We Collect; How We Collect It; How We Use It

General information regarding our collection, use, and disclosure of personal information is set forth in the Privacy Policy above.

In the past 12 months, we have collected categories of personal information described in the section of the Privacy Policy above titled Personal Information We Collect From You, and we have collected this information from the sources described in the section titled How We Collect Your Personal Information. Depending on your level of interaction with us, we may not have collected your personal information from all of the categories listed in the Privacy Policy above. We collect and use your personal information for the business or commercial purposes described in the section titled How We Use Your Personal Information, and retain it pursuant to the section titled Data Retention.

We disclose the following categories of personal information for business or commercial purposes to the categories of recipients listed below:

Disclosure of Personal Information

Company may disclose your personal information to a third party for a business purpose, or “sell” or “share” your personal information, subject to your right to opt out (see Right to Opt Out of Selling or Sharing Your Personal Information, below). The CCPA defines “sell” and “share” much differently that you would intuitively think.  We do not sell your personal information by itself to other parties for money, but we may engage in targeted advertising using a cookie or IP address.  That may be considered selling or sharing your personal information under the CCPA.  The information above under Information We Collect; How We Collect It; How We Use It describes the entities with which we may disclose your personal information.

Rights to Your Information

  1. Right to Know

As a California consumer, you have the right to request that we disclose certain information to you about our collection, use, or disclosure of your personal information. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights, below), and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:

  1. Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights, below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. However, we may retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under the CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.

  1. Right to Data Portability

You have the right to request a copy of personal information we have collected and maintained about you. The CCPA allows you to request your information from us up to twice during a 12-month period. We will provide our response in a readily usable (and usually electronic) format.

  1. Right to Correct

You have the right to request the correction of any personal information we maintain about you.

  1. Right to Opt Out of Selling or Sharing Your Personal Information

You have the right to opt out of the sale or sharing of your personal information, along with the right to opt in to the sale or sharing of such information.  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 (the “right to opt-in”) from either the consumer who is less than 16 (but greater than 13) years of age, or the parent or guardian of a consumer less than 13 years of age. To our knowledge, we do not sell or share the personal information of minors under 16 years of age.

To exercise the right to opt out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page: “Your Privacy Choices.” We will also treat opt-out preference signals (such as Global Privacy Control)  from browsers as valid opt-out requests. You may change your mind and opt back into personal information sales at any time by contacting us at info@rational360.com.

  1. Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

  1. Exercising Your Rights

To exercise the rights described above, please contact us by using the following methods:

After submitting a request, we will take steps to verify your identity in order for us to properly respond and confirm that it is not a fraudulent request. In order to verify your identity, we will ask, at a minimum, that you provide your name, email address, and relationship to us, so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal information, we may contact you for more information, or we may not be able to meet your request.

Only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your personal information. If you are making a request as the authorized agent of a California consumer, we will ask you also submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf.

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the CCPA allows us up to 90 days to respond. We will still contact you within 45 days from when you contacted us to let you know we need more time to respond.

EUROPEAN PRIVACY RIGHTS

IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM, THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

Legal Basis

We will only use your personal data, as that term is defined under the General Data Protection Regulation (“GDPR”), when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

To the extent permitted under applicable laws, we will also process, transfer, disclose, and preserve personal data when we have a good faith belief that doing so is necessary.

Data Controller

Rational360 is the data controller of all personal data collected through our Services. To contact us, please see the section below titled Contacting Us.

If you are situated in the EEA, Switzerland, or the UK and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us in the first instance. If you have a complaint, please contact our privacy manager here: info@rational360.com.

Provision of personal data and failure to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you.

Collection of personal data from third-party sources

We may obtain personal data and other information about you public sources and through our third-party partners who help us provide our services to you.

Withdrawing your consent

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at info@rational360.com.

Data Transfer

We may transfer personal data from the EEA, Switzerland, and the UK to the USA and other countries, some of which have not been determined by the European Commission or the UK Secretary of State to have an adequate level of data protection. Where we use certain vendors, we may use specific contracts approved by the European Commission or the UK Secretary of State which give personal data the same protection it has in Europe. For more information about how we transfer your data, please contact us at info@rational360.com.

Use of your personal data for marketing purposes

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

Data Subject Rights

If you are situated in the European Union, Switzerland, or the UK, under the GDPR, as a data subject, you have the right to:

To exercise your rights under the GDPR, please contact us at info@rational360.com. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.

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