Last Updated: January 29, 2020

Privacy Policy Effective Date: January 29, 2020

This Privacy Policy which details important information regarding the use and disclosure of user information collected on the website getrighty.com, which is owned and operated by Righty, Inc. (“Righty”, “we” or “us”) on behalf of itself, its affiliates, and any successor website (collectively the “Site”), and other Righty interactive properties, including but not limited to any downloadable or non-downloadable mobile applications enabling you, the User (“you”, “your”, or “User”), access to the Site and other Righty features (the Site and other Righty interactive properties are collectively referred to herein as the “Righty Applications”). Righty provides this Privacy Policy to help you make an informed decision about whether to use, or continue to use, the products and services provided by Righty and/or accessed through the Righty Applications or offline (“Product(s)” and “Service(s)”). This Privacy Policy applies to your use of (1) the Righty Applications (however accessed and/or used, whether via personal computers, mobile devices or otherwise); (2) our Products and Services; (3) email or electronic catalogs and newsletters; (4) offline means such as direct mail, telephone and postal mail; and (5) any other means or applications in which you connect with Righty. By accessing, using, registering with, or providing personal information to Righty, you explicitly accept, without limitation or qualification, the collection, use, storage and transfer (including international transfer) of user information in the manner described in this Privacy Policy (as amended from time to time). THIS PRIVACY POLICY AFFECTS YOUR RIGHTS AND LIABILITIES UNDER THE LAW. If you do not agree to the terms of this Privacy Policy, do not access or use the Righty Applications or provide us with personal information.

Effective Date and Changes

This Policy applies to all information collected by or provided to us on or after the Effective Date. Righty will periodically review and revise this Policy and update the Policy modification date below. If we materially change this Policy in a way that affects how we use or disclose your Personal Information, we will notify you of such changes before your next use of the platform and by stating the effective date of the changes. We will treat your continued use of the Righty Platform following such changes as your acceptance of them. We encourage you to periodically review this Policy.

If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than those policies in effect at the time we collected the information, we will make reasonable efforts to provide notice and to obtain consent to any such uses as may be required by law, but we will not be liable for any failure to do so.

INFORMATION WE COLLECT

We may collect different types of information, including, but not limited to, personal information, financial information, demographic information, log, Device (hereinafter defined) and aggregate data. Sometimes we collect combinations of all these types of information. In each case, when using the Righty Applications, it is indicated on the Righty Applications whether any personal or demographic data must be provided for you to access and use the Righty Applications and/or purchase the requested Product or Service.

Righty Applications and Information Provided by You

When You Register or Otherwise Contact Us.

When you provide us with information in connection with a particular activity or otherwise sign up for or order our Products and Services or provide your contact information, including an email address or telephone number in connection with that activity, product or service, you agree that this action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to our communicating with you about Righty using the information you provided to us. You also attest that you have the legal authority over any telephone number you provide to us and can provide us with the authorization to contact you. This means we may contact you, in person or by recorded message, by e-mail, telephone and/or mobile telephone number (including use of automated dialing equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving.

Information You Provide Us – Registration[JH1]  Information.

We will collect personal information from you if you (1) establish a Righty membership account, which is governed by the Righty Membership Agreement (the “Membership Agreement”), (2) otherwise register with the Righty Applications and/or (3) place an order for our Products or Services, which may include, but is not limited to, name, address, phone number(s), email address(es), personal interest preferences, and any other information about you we consider relevant (“Personal Information”). You may not use a user/account name that is vulgar or otherwise offensive (as determined by Righty), infringes any trademark or other proprietary rights of others, or is used in any way that violates the Membership Agreement or the Terms of Use (“Terms of Use”). Righty reserves the right to deny, in its sole discretion, any user access to the Righty Applications and/or our Products and Services without notice for any or no reason.

Righty Pro Registration and Payment: To register as a Righty Pro, you may need to provide additional Personal Information, including your profile picture and ID for verification purposes, payment information, and Social Security number; in some jurisdictions we may collect additional business or contractor licenses. Righty Pros may enter a bio line during the registration process which may or may not include Personal Information.

Transaction Information: We collect transaction details related to your use of the Righty Platform, such as type of service requested, date and time of service, amount charged, location, distance traveled, intra-User communications, ratings and reviews, and other related transaction details.

Customer Support: We may collect Personal Information such as your name, email address, phone number, and photographs through your communications with our Righty Support team.

Information to be published or displayed (“User Contributions”): Your User Contributions are posted on and transmitted to others at your own risk. Righty, cannot control the actions of other Users of the Website or Platforms with whom you share your User Contributions. For additional information on User Contributions, please see our Terms of Use.

Identification & Financial Information: you may need to provide additional Personal Information, including your profile picture and ID for verification purposes, payment information, and Social Security number; in some jurisdictions we may collect additional business or contractor licenses, if applicable. You may enter a bio line during the registration process which may or may not include Personal Information.

Financial information is information that you provide to us, including your debit, credit card number, bank account information and related billing information (collectively, the “Billing Information”). We require such financial information in order to process payment for the purchase of a Product or Service that you have requested. By submitting your financial information, you consent to our providing it to those Authorized Third Party Service Providers (as later defined) as necessary to support and process your transactions as well as your credit card issuer/banking institution for their purposes.

We ask that you do not enter financial information into your profile, except in the fields provided for that information.

Facebook & Google. You may be given the option to link your Facebook and/or Google account so that you can comment or leave reviews on the Righty Applications and/or our Products and Services or take advantage of other features of the Righty Applications. When you comment or leave reviews on the Righty Applications using your Facebook and/or Google username and password and clicking “allow” on the Facebook and/or Google permission authorization screen, we will automatically import whatever information that you allow to be imported from your Facebook and/or Google profile based upon your privacy settings at Facebook and/or Google, such as your location, your interests, etc. (collectively, “Permitted Facebook & Google Profile Content”) and you give us permission to capture, store, use and display your Permitted Facebook & Google Profile Content, including syncing access to such Permitted Facebook & Google Profile Content when you are not using Righty Applications and we may share that information with other users. The authentication of your Facebook & Google login credentials is conducted solely through Facebook and/or Google.

User Generated Content.

The Righty Applications may contain review or chat areas and/or other message, communication or other mechanisms designed to enable you to communicate with others or to post content on the Righty [JH2] Applications (the “Communication Services”). Please remember that any information you disclose while participating with the Communication Services becomes public information, becomes the property of, and is subject to redistribution by, Righty. You should exercise caution and discretion when deciding to disclose your personal information in a submission or posting. There is no expectation of privacy when posting or otherwise participating on the Communication Services. If you post content, such as messages, reviews or photos, please be aware that any personally identifiable information contained in such content is accessible to registered users or visitors to that Righty Application or Communication Services and we have no control over how those users may use your personally identifiable information. We have the right, but not the obligation, to monitor any activity and content associated with the Communication Services. We reserve the right to act in connection with any content we deem to be inappropriate. Please review our Terms of Use for more information regarding your appropriate use of these Communication Services.

Information Collected Through Technology

In addition to any Personal Information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs. As you use our Righty Applications, your browser and devices communicate with servers operated by us, our business partners and our Product and Service providers to coordinate and record the activity and fill your requests for our Products and Services and information (“Usage Information”). We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access our Righty Applications, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. In addition, we collect your IP address or other unique identifier (“Device Identifier”) for your computer or other device used to access the Righty Applications (any, a “Device”). A Device Identifier is a number that is automatically assigned to the Device used to access the Righty Applications, and our computers identify your Device by its Device Identifier. We may also collect information about the website you were visiting before you came to our Righty Applications and the website you visit after you leave our Righty Applications, if this information is supplied to us by your browser. We may use this Usage Information for a variety of purposes, including to enhance or otherwise improve the Righty Applications.

The information from cookies and related technology is stored in web server logs and also in web cookies kept on your Device(s), which are then transmitted back to our Site by your Device(s). These servers are operated, and the cookies managed by us, our business partners or our service providers. For example, when you visit Righty Applications, we and our service providers may place cookies on your Device(s). Cookies allow us to recognize you when you return and may track and target your interests in order to provide a customized experience. They also help us detect certain kinds of fraud. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Righty Applications. Some cookies contain serial numbers that allow us to connect your activity with Righty Applications with other information we store about you in your profile or as related to your interactions with Righty Applications.

Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases Session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use Persistent cookies for a number of purposes, such as retrieving certain information you have previously provided. “Flash” cookies, known as local shared objects, are data files placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device to personalize your visit. Our third-party service providers also may use Flash cookies to collect and store information. Flash cookies are different from standard browser cookies because of the amount of, type of, and how data is stored. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. You can choose to have your computer warn you each time a Persistent or Session cookie is being sent, or you can choose to turn off such cookies through your browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. However, cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies, please click www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you choose to disable cookies on your Device, some features of the Righty Applications may not function properly. For instance, if cookies are disabled, you will not be able to log into the Site and therefore you will experience an anonymous user experience.

Pixel tags and web beacons are tiny graphic images placed on the Righty Applications or in our emails that allow us to determine whether you have performed specific actions. When you access the Righty Applications or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure response to our communications and improve the Righty Applications and promotions.

We also may use embedded scripts which are programming codes designed to collect information about your interactions with the Righty Applications, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Righty Applications, and is deactivated or deleted thereafter.

Location Information:  We also may collect precise location data through the Righty Applications when it is used by Righty Members, Righty Pros and Righty Pro Technician, if Righty Members, Righty Pros and Righty Pro Technician devices permit such information collection. We may collect this information when certain functionalities are used, such as selecting “my location” or navigating to a location to provide the Services, and we may also collect the precise location of you or a Righty Pro or Righty Pro Technician’s device when the App is running in the foreground or background. We may derive a Righty Pro or Righty Pro Technician’s approximate location from the Righty Pro or Righty Pro Technician’s IP address. The Righty Platform utilizes geo-location features to connect Righty Members to Righty Pro and Righty Pro Technicians, to update Righty Members on the status of Righty Pro or Righty Pro Technician’s en route to perform Services, to confirm they performed Services, and to improve the services on the Righty Platform.

We also may use and disclose geo-location we collect through the Righty Platform for other business purposes, including for legal purposes (such as to enforce our agreements) and in the event of a proposed or actual merger, sale, or other business asset transfers. The geo-location information obtained about a User will be retained in an identifiable manner, along with geo-location data about job sites where Righty Pro and Righty Pro Technician’s performed Services on initial and/or follow-up jobs.

Device Information: We may collect information about your mobile device, including the following examples: the hardware model, operating system/version, software names/versions, file names/versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.

Usage and Preference Information:  We collect information that is generated automatically about how you and visitors interact with the Righty Platform, preferences expressed, and settings chosen. When we associate such information with specific personal information, we will treat the combination as Personal Information, as set forth herein.

Communications Between Users: As an enhanced privacy feature, we use a third-party service called Twilio to mask the telephone numbers used during calls or texts (SMS) between Users (See additional provisions regarding Twilio herein below). We do not reveal telephone numbers submitted on file, although we store any call data, including associated date, time, and content.

Information You Provide About a Third Party

If you send someone else a communication from the Righty Applications, such as sending an invitation to a friend, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. If that person becomes a customer or registers with us, his/her information will be treated in the same manner as all other customers or registered users. Please be aware that when you use any send-to-a-friend functionality on the Righty Applications, your e-mail address may be included in the communication sent to your friend.

Information We Collect from Third Parties, Righty Pros and Righty Pros Technicians

We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as information to validate or update your address or other demographic and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, our Products and Services and offers that may be of interest, and for internal business analysis or other business purposes.

Righty engages with third-party service providers that provide information that makes it possible to run elemental aspects of the Righty Platform, as well as additional services such as loyalty programs and promotions.

Some of the things these Righty Pro and Righty Pro Technicians allow for are background checks, payment processing, insurance, marketing, and other businesses. Information we receive from these third parties includes:

·         Safety and Security Information, such as background checks;

·         Third party program participation information, such as transactions and fraud detection; and

·         Operational information for loyalty and promotional programs, such as your use of such programs.

Referral Programs: Your endorsement is a valued compliment. We collect information when Users of the Righty Platform refer us to others including the use of a personalized code to share with others.

Third-Party Site Account Access:  If you log in to the Righty Platform through a social networking site, such as Google or Facebook, we may collect your authentication token, registration information, and account identification number and use that information to provide you with access to your account on the Righty Platform.

Other Uses and Sources: At times, other users and sources such as the media, insurance companies, and law enforcement may provide information about you or prior activities during incident research.

Third Party Analytic Technologies

We use third parties’ analytic and tracking tools to better understand who is using the Righty Applications, how people are using the Righty Applications and how to improve the effectiveness of the Righty Applications and its content, and to help those parties serve more targeted advertising to you across the Internet or help us serve more targeted advertising to you. Those third party companies may use cookies, pixel tags or other technologies to collect and store anonymous information such as time of visit, pages visited, time spent on each page of the Righty Applications, Device Identifiers, type of operating system used and other website(s) you may have visited. They might combine information they collect from your interaction with Righty Applications with personal information they collect from other sources, and use this combined information to send you relevant marketing, including by email, about products and services of ours or of third parties. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies. If you wish to exercise choice with respect to collection and use of the data by these third party tools, you may visit: http: //www.aboutads.info/choices/ Some of the analytic and tracking tools we use are Google Analytics and Google Analytics Advertising. The Google Analytics Advertising features we use include the following:

Remarketing Google Display Network Impression Reporting Google Analytics Demographic and Interest Reporting Integrated services that require Google Analytics to collect data via advertising cookies and anonymous identifiers If you wish to manage your Google accounts, you may visit: https: //www.google.com/settings/u/0/ads/authenticated If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout/

HOW WE USE AND SHARE YOUR INFORMATION

We use your information, subject to applicable laws, in the following ways: to allow you to register and create an account and profile; for administrative functions that may be performed by Righty, Inc. or its subsidiaries; to deliver, provide or process payments for a product or service you have requested; to enable you to provide us with feedback, to contact us and for us to contact you; to administer promotions you enter such as a contest or sweepstakes; to allow your participation in our Communications Services (where available on the Righty Applications); to allow your participation in any surveys; to send you maintenance communications to alert you to changes and updates in our Righty Applications’ policies, Products and/or Services that may affect you; to send you communications of interest that you have requested, such as emails or text messages about Righty, our Products and/or Services, targeted marketing, and promotional offers; to customize, measure and improve our Products and/or Services, content, and advertising, including generating internal reports about the use of our Righty Applications; to personalize your overall experience with the Righty Applications; to enforce our Membership Agreement or Terms of Use; for purposes disclosed at the time you provide your information; and as otherwise set forth in this Privacy Policy.

As set forth herein, we do not rent, sell, or share Personal Information (as defined by California Civil Code § 1798.83) about you with other people or nonaffiliated companies for their direct marketing purposes unless we have your permission. We may allow access to other data collected by the Righty Platform to enable the delivery of our online advertising on the Righty Platform and on other websites and online services, or to send you information we think may be useful or relevant to you.

Before we disclose Personal Information with Righty Pros or Righty Pro Technicians for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract[JH3] .

The following are examples of how we use and/or share your information with third-party service providers.

Transactional Communications. We may send you notices from time to time relating to your account or your orders. These may include order confirmations, invoices, renewals or customer service notifications. We may also send you service-related announcements when it is necessary to do so; for instance, if our Service(s) is/are temporarily suspended for maintenance, or the delivery of a Product is delayed or there is some service issue with something you may have ordered. You may not opt-out of receiving these communications, which are not promotional in nature.  

Authorized Third Party Service Providers. We may use third party service providers (“Authorized Third Party Service Providers”) to help us operate our business and the Righty Applications or administer activities on our behalf. We may share your information with these third parties.

Third Parties Who Recommended our Products and Services. From time to time we may provide to third parties who either purchased on your behalf, or recommended our Products and Services to you, (such as realtors who sold or rented you your home) information regarding your use of those products or services. If you wish to opt out of us providing this information to those third parties, you may opt-out as provided in the CHOICE AND OPT OUT section below.

Electronic Promotional Offers. We may send you promotional emails or notification on your mobile application regarding special offers about our Products and Services or on behalf of third party marketing partners who we think can offer services and products of interest to you. If you do not want to receive emails from us regarding special promotions or offers, or from any third party, you may opt-out as provided in the CHOICE AND OPT OUT section below.

Sharing Information with Third Parties. Subject in all cases to applicable law, we may send you offers through direct mail, email or other means that we feel might be of interest to you and/or sell, share or rent your name, mailing address, email address and certain other information, such as what you ordered, with reputable companies that provide marketing offers. If you do not want us to send you offers or share your Personal Information with other companies, you may opt-out as provided in the CHOICE AND OPT OUT section below.

Telemarketing. If you have given us your telephone number, when making an inquiry or registering with us or when ordering Products or Services from us, we may use the telephone number you provided to reach out to you to follow up on your order, including follow-up regarding renewals and marketing. If you would prefer not to receive marketing phone calls from us, you may opt-out as provided in the CHOICE AND OPT OUT section below.

Third Party Tracking and Advertising. We may allow third-party companies to serve ads and/or collect certain anonymous information when you visit the Righty Applications. These companies may use non-personally identifiable information (i.e. click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Righty Applications and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie or third party web beacon to collect this information. If you would like more information about advertisers’ use of tracking technologies and about your option not to accept the cookies used to track your activities, you can go to www.networkadvertising.org.

Co-branded Areas. Certain areas on our Righty Applications may be provided to you in association with third parties such as advertisers which provide products and services or rewards programs (“Co-Branded Areas”). Such Co-Branded Areas will identify the third party. If you elect to register for the products and/or our Products and Services provided at these Co-Branded Areas, you either will be providing your Personal Information to both us and the third party or we might be providing your Personal Information directly to the third party in order for that third party to fulfill their products and our Products and Services directly with you. Your Personal Information will be subject to this Privacy Policy as well as the privacy policy and practices of such third party. We are not responsible for the privacy practices of those third parties and we suggest you review the individual privacy policies of each company with whom you establish a relationship. You should consult the respective privacy policies of those third party sponsors or advertisers to learn more about their privacy practices.

Feedback. All comments, feedback or materials submitted by you to us, including feedback, testimonials, images, reviews, questions, comments, suggestions or ideas (collectively, “Feedback”), shall be received and treated by us on a non-confidential and unrestricted basis. Righty will be free to use, display, perform, distribute, copy, adapt, and promote, in any medium now known or later developed, without compensation to you, the Feedback along with all ideas, concepts, know-how, techniques or methodologies contained in such Feedback, for any purpose whatsoever, including without limitation, developing, marketing and selling our Products and Services incorporating such Feedback. You agree that in submitting Feedback, it will not violate any right of any third party, including any confidentiality, copyright, trademark, privacy or other personal or intellectual property or proprietary rights, and will not cause injury to any person or entity. You further agree that no Feedback you submit will be or contain libelous or otherwise unlawful, threatening, abusive or obscene material, or contain viruses, commercial solicitations, or any form of “spam.”

Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion and as required by law or permitted by the Promotion’s official rules. In addition, if you choose to enter a Promotion, the Personal Information you provide to us will be used by us in accordance with the terms of this Privacy Policy.

Legal Matters; Safety. We may, without your consent, access and disclose your information, any communications sent or received by you (including, without limitation, the contents of any chat, messaging, or other communication posted in the Communication Services), and any other information that we may have about you or your account as may be permitted or required by law (including, but not limited to, court order or subpoena), or to prevent or investigate suspected fraud, violations of our Membership Agreement or Terms of Use or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your information and/or communications in situations that we believe to be: (i) emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat; or (ii) your conduct on the Righty Applications or when using the Communication Services that we believe is inappropriate and inconsistent with generally accepted norms of behavior.

Sale or Transfer of Business or Assets. In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, personally identifiable information (including all Personal Information) of our customers and visitors to our Righty Applications may be one of the assets sold or merged in connection with that transaction. In addition, information about our customers and registered users may also be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding.

Use of your information also allows us to:

·         Meet or fulfill the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase or provide a product or service, we will use that information to communicate Service requests from you to other Users, and/or suggest potential Customers for your Services as well as process your payment and facilitate delivery. We may also save your information to facilitate new service orders or address disputes;

·         Provide, support, personalize, and develop our Website, products, and services. We may use your phone number or email address to contact you in connection with your Righty-related activities (including, but not limited to, confirmation emails, account verification text messages, push notification alerts, or important alerts that could affect your relationship with Righty);

·         Create, maintain, customize, and secure your account with us;

·         Personalize your platform experience and deliver content and product and service offering relevant to your interests, including targeted offers and ads through our platform, third-party sites, and via email or text message (with your consent, where required by law);

·         Enable testing, research, analysis, and product development, including to develop and improve our Platform, products, and services. For instance, to continuously evaluate and improve the online and mobile user experience. We use platform analytics and marketing to advertise, promote and market Righty services and products;

Sharing Between Righty Platform Users. We may display to our Righty Members certain information about our Righty Pros and Righty Pro Technicians, namely, your name, photograph, geo-location, and rating if applicable, and such information may also be visible to users of our Platform Partners’ websites. When you submit a Service request as a Righty Member, we will display certain information about you to Righty Pros and Righty Pro Technicians, including your name, address, photograph (if any), rating, and photographs of the Service Job. Righty Members’ full address is disclosed only to the selected Righty Pro or Righty Pro Technician.  Righty discourages the sharing of any additional contact information between Users of the Righty Platform.

 

Sharing with Righty Pros, Righty Pro Technicians and Third Parties for a Business Purpose. Categories of information we share to operate the Righty Platform, including processing your transactions and supporting your activities on the Righty Platform, we may disclose the following categories of your Personal Information with vendors, agents, and third-party service providers for the following business purposes:

·         Category A: Identifiers:  A real name, alias, postal address, unique personal identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license, passport number, or other similar identifiers.

·         Category B: Personal information categories listed in the California Consumer Records Statute §(Cal. Civ. Code 1798.80(e)):  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.

·         Category D: Commercial Information:  Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

·         Category E: Internet or other similar network activity:  Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

·         Category F: Geolocation Data:  Physical location or movements.

·         Category G: Inferences drawn from other personal information:  reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Business Purposes for Disclosing Information:  We may use or disclose the Personal Information we collect for one or more of the following business purposes:

·         To fulfill or meet the reason you provided the information.  If you provide your Personal Information to purchase or provide a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new service orders or address disputes.

·         Righty Payment Method:  When you add a credit card or payment method to your Righty account, a third party that handles payments for us will receive your card information. To keep your financial data secure, we do not store full credit card information on our servers.

·         To provide, support, personalize, and develop our Website, products, and services.

·         Operating Systems and Platforms.  We use Amazon Web Services and DigitalOcean to host the cloud architecture for the Righty Platform. We use Google Drive, GSuite, WhatsApp, One Drive, Slack and Asana in the daily course of business operations. Files and data stored in those systems may include customer name, postal address, telephone number, email address, personal identifier/account ID, device ID, IP address, IDFA, and date of birth.

To create, maintain, customize, and secure your account with us.

·         Platform Features.  We use Twilio for a few reasons, which may include, registration of new Users to make sure your contact information is accurate and that every new User account in our system is an actual person we can serve. We also have the ability to use Twilio for masking your telephone number when you call or text (SMS) message another User using the telephone number provided by Righty through the Righty Applications. You can find information about Twilio's privacy practice at:  https: //www.twilio.com/legal/privacy. We also may use the Google Maps service, and you agree to the Google Maps/Google Earth Additional Terms of Service located at  https: //maps.google.com/help/terms_maps.html and Google's privacy policy located at http://www.google.com/policies/privacy. We may use other programs as well like tawk, sendbird, Callhippo  

To process your requests, purchases, transactions, and payment and prevent transaction fraud.

·         Payment Processors. We use Stripe to process any billing information between Users and between Users and us, including credit card information Users submit. You can find information about Stripe's privacy practice at https://stripe.com/us/privacy.

To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

·         Customer Relationship Management Platform Hosts.  We will use a customer engagement platform via email and live chat. Information collected in correspondence through this platform usually includes name, email address, Device ID, and IP address as well as any information you share in correspondence such as pictures, addresses, or biographical information.

·         Order Fulfillment Platforms.  We may occasionally share the name and address of Users to order fulfillment platforms in order for them to ship items to Users.

To personalize your Righty Platform experience and to deliver content and products and service offerings relevant to your interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message (with your consent, where required by law).

·         Charitable Donation Programs:  We may offer opportunities within the Righty Platform for Users to donate to charitable organizations. If you voluntarily agree to donate to a charitable organization by taking affirmative steps within the Righty Platform, then you hereby authorize Righty to provide your Information to such charitable organization to facilitate your donation to their charitable campaign.

To help maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, and business.

·         Background Check Processors.  We use manual look-up processes as well as we may use Checkr and Evident for purposes of performing background checks on Righty Pros and Righty Pro Technicians that register to perform Services for Righty Members on the Righty Platform. You can find information about Checkr's privacy practice at:  https://checkr.com/privacy-policy/ and Evident's privacy practice at https://www.evidentid.com/privacy-policy/.

Application and Data Security Entities. We will use a security consulting and testing company who may on occasion have temporary access to contact information including names, aliases, addresses, email addresses, and phone numbers; account names or ID numbers; IP addresses or IDFAs; government ID cards; consumer history on the Platform including purchases, browsing history, physical location or movements; current or past history or performance evaluations; audio, electronic, visual, thermal, olfactory, or similar information; or profiles. We will use a real-time Application Security Management Platform which receives partial postal address, email address, physical location or movements, and IP addresses.

·         Insurance providers.  In the event of an insurance claim, we would provide the information necessary for reporting and documentation, including name and address.

·         External mediators.  We use a third-party mediator to resolve disputes between Customers and Providers when necessary. Righty shares the name, address, phone number, and email address of Users with such third-party mediator service providers.

·         For testing, research, analysis, and product development, including to develop and improve our platform, products, and services.  We may use the information we collect for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

·         Data analytics providers.  We retain third-party service providers to help us perform data analytics regarding your interactions with the Righty Platform. For example, we use Google Analytics Service for purposes of analyzing usage of the Righty Platform. You can find information about Google's privacy practice at: https://www.google.com/policies/privacy/partners.

Platform Partners. Some third-party sites link to the Righty Platform and share information with Righty. For example, in some cases, you can schedule services through the Righty Platform with one of our partners (“Platform Partner”). In that case, you might provide the job information, such as your name, telephone number, email address, and service address, to the Platform Partner. The Platform Partner might then share the necessary booking information with us. Conversely, we share your Personal Information with Platform Partners. Upon request, we provide our Platform Partner with information about the services you booked or provided, as applicable, through the Righty Platform.

How We Store and Protect Your Information

·         Information Retention. To preserve the integrity of our databases, standard procedure calls for us to retain information submitted by members for an indefinite length of time. You agree that we may store the information we collect for this indefinite length of time.

·         Our Security Precautions Your Righty profile is password-protected so that only you and authorized Righty employees have access to your account information. In order to maintain this protection, do not give your password to anyone. Righty staff will never proactively reach out to you and ask for any personal account information, including your password. If you share a computer or mobile device, in order to protect your information entered on public terminals from disclosure to third parties, you should sign out of your Righty account and close the browser window before someone else logs on. Righty has security measures in place intended to help protect against the loss, misuse, and alteration of the information under our control.

International.  Your information may be transferred to and maintained on computer networks which may be located outside of the state, province, or other governmental jurisdiction in which you reside; and the privacy laws governing the country/jurisdiction of these computer networks may be less protective.

Righty takes steps to ensure that your information is secure on its system. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Righty cannot guarantee the security of any information you transmit to us, and you do so at your own risk. RIGHTY EXPRESSLY DISCLAIMS ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESSED OR IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING, OR OTHERWISE OFFERING ANY DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR PERSONAL INFORMATION OR USAGE INFORMATION AND FURTHER DISCLAIMS ANY LIABILITY THAT MAY ARISE SHOULD ANY OTHER INDIVIDUALS OBTAIN THE INFORMATION YOU SUBMIT TO THE RIGHTY PLATFORM

Your Rights and Choices Regarding Your Data

All Users

·         Email Subscriptions.  Righty provides Users the opportunity to unsubscribe from email marketing communications from us and our partners and gives Users the option to remove their information from our database, to not receive future email marketing communications, or to no longer receive our service. If you receive an unsolicited marketing email from a Righty email address, please contact Righty at support@getrighty.com with the subject line “Unsolicited Marketing Removal.”

·         SMS Messages.  You can adjust the SMS messages that you receive through Settings in the Platform. This may result in not receiving important updates regarding your appointments and account activity.

·         Push Notifications.  You can deactivate push notifications for marketing. Push notifications for important updates regarding your appointments and account activity are required for proper functioning of the Platform.

·         Profile Information.  Righty provides you with the ability to access and edit your Personal Information: Sign into the App, access the Settings menu, and then view and update/correct your account information. So that we can protect the integrity of sensitive data, there are certain pieces of information, such as your age, that you cannot alter yourself. Please contact us at  support@getrighty.com  to change information you cannot access through your account with the subject line “Profile Change.”

·         Location Information.  You can stop your device from sharing location information via the system settings, although this could impact the full range of services and features available through the Platform.

·         Cookies, Web Beacons, and Other Technologies.  Like most online services and mobile applications, we and our third-party service providers may use cookies, web beacons, and similar tracking technologies to collect information about your activity from the computer or devices you use to access the Righty Platform. As mentioned before, a cookie is a file saved on a User’s hard drive that stores certain information about User activity. Users must agree to let cookies be saved for them, and most web browsers are set to accept cookies by default. Although you can modify your browser/device settings to reject cookies if desired, this could potentially affect the availability and functionality of our services.

Any third party with whom we are allowed to share your Personal Information is authorized to use your Personal Information in accordance with our contractual arrangements with such third parties and in accordance with their own privacy policies, over which we have no control. You agree that we are not responsible or liable for any of their actions or omissions. Those who contact you will need to be instructed directly by you regarding your preferences for the use of your Personal Information by them.

·         Do Not Track.  You may be able to activate the “Do Not Track” option through your web browser.

·         Deleting Your Account.  If you would like to delete your account, please submit a request by logging into your account and submitting under Settings, or sending an email to  support@getrighty.com with the subject line “Delete my Account”. Once we receive and verify your consumer request, we will delete (and direct our service providers to delete as applicable) your Personal Information from our records, unless an exception applies. If we are unable to delete your account in whole or in part due to legal obligations or the certain other exceptions, we retain data in a way designed to prevent its use for other purposes.

·         Advertising Opt-Out.  You may be able to opt out of receiving personalized advertisements from advertisers and/or advertising networks who are either members of the Network Advertising Initiative or subscribers to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. To learn more about your choices for opting out of personalized advertising through websites and/or apps, please visit:

·         Network Advertising Initiative (NAI)

·         Browser Opt-Out:  http: //www.networkadvertising.org/choices/

·         Digital Advertising Alliance (DAA)

·         Browser Opt-Out:  http: //www.aboutads.info/choices/

·         App Opt-Out:  http: //youradchoices.com/appchoices

You may also be able to change your mobile device settings to Opt-Out of personalized advertising through apps. For example, for iOS mobile devices, go to “Settings” from your device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” Also, for location-based ads, you may go to “Settings” from your device’s home screen; select “Privacy”; select “Location Services”; select “System Services”; and de-select “Location-Based Apple Ads.” For Android mobile devices, go to “Google Settings” on your device; select “Ads”; and check the box labeled “Opt-Out of Interest-Based Ads.”

Please note that when you Opt-Out of personalized advertising, you may continue to see online advertising on the Righty Platform and/or our ads on other Internet websites.

If you have an online account with us, you may choose to resign and deactivate or otherwise manage your account at any time. Please visit My Account. If for any reason you are concerned that the Personal Information or Billing Information you provided to us is not correct and you wish to change it, please call our Customer Care Department at 305-520-7520. We will be happy to review, update or remove information as appropriate. If you deactivate your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, resolve disputes, enforce our Membership Agreement, Terms of Use or other policies, take actions we deem necessary due to technical and legal requirements, and as dictated by constraints related to the security, integrity and operation of our Righty Applications. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies. We may still retain your information in our files however, to resolve disputes and enforce our Membership Agreement or Terms of Use.

To opt-out of marketing communications or to request to be added to our Do Not Call List, and/or our Do Not Mail List, you may use one of these convenient methods:

Electronic Promotional Offers. If you do not want to receive emails from us or from any third party regarding special promotions or offers, you may (i) click the unsubscribe link in the footer of any email (ii) call our customer care at 305-520-7520 or (iii) contact our Privacy Coordinator at the address set forth below.

Direct Mail Promotional Offers. If you do not want us to send you any promotional offers through direct mail or sell, rent or share your Personal Information with other companies so that they can send you direct mail offers about their products and services, you may: (i) call customer care at 305-520-7520; or (ii) contact our Privacy Coordinator at the address set forth below.

Telemarketing. If you do not want to receive marketing phone calls from us, you may: (i) call customer care 305-520-7520; (ii) ask to be placed on our Do Not Call list when you receive a call from us; or (iii) contact our Privacy Coordinator at the address set forth below.

Third Parties Who Recommended our Products and Services.

If you wish to opt out of us providing this information to such third parties, you may: (i) call customer care at 305-520-7520; or (ii) contact our Privacy Coordinator at the address set forth below. If you receive marketing communications from Righty or one of its affiliates, you must opt-out individually from each of the brands from which you are receiving brand-specific marketing communications. Please note that even if you opt out of receiving promotional electronic or direct mail offers, we may continue to send you service notifications by email or direct mail that are related to your account(s) and our Products and Services you have requested or in which you are currently enrolled.

IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION

Links to other Website(s) and Communities.

To the extent hyperlinks may be utilized to access external or third party website(s) and communities, you should be aware that these external or third party website(s) and communities are not controlled by us and, therefore, are not subject to this Privacy Policy. We recommend that you check the privacy policies of each such website and community to determine how your personal information will be utilized by their proprietors. Security. We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of information transmitted to us. Also remember to log off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place.

Special Notice to California Residents.

Customers residing in California who have submitted Personal Information to us may request information about our disclosures of certain categories of personal information to third parties for direct marketing purposes. All requests for disclosure information must be submitted to the Privacy Coordinator at the address set forth below. Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. As of the date of this Privacy Policy, except as otherwise provided in this Privacy Policy, we do not respond to “Do Not Track” requests. A

Children's Privacy.

The Righty Applications are generally intended for general adult audiences and are not directed or intended for children under 13 years of age. We do not knowingly collect Personal Information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide Personal Information on the Righty Applications. If we later obtain actual knowledge that a user who has provided Personal Information is under 13 years of age, we will take steps to remove that user’s Personal Information from our systems.

 

Disputes. If you choose to visit the Righty Applications your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use including limitations on damages, resolution of disputes, and application of the laws of the United States and the State of Florida.

No Rights of Third Parties. This Privacy Policy does not create rights enforceable by third parties or require disclosure of any Personal Information relating to users of the Righty Applications.

Contacting Us. If you have any questions about this Privacy Policy, or the practices of the Righty Applications and Righty Platform, please email us at support@getrighty.com with, if not otherwise noted, the subject line, “PRIVACY POLICY” or write to us at:

Office of Righty Legal

Attn: Righty Legal Team – Righty, Inc. 14 NE 1st Street Suite 1105 Miami, FL 33139
©2019 Righty, Inc. All rights reserved.