Effective Date: April
15, 2023.
The Russo Group, its
subsidiaries and affiliates (collectively,
“TRG”, “us” or “we”) understand that your privacy is important to you. We are
committed to respecting your privacy and protecting your personal data, which
is any information that is capable of identifying you as an individual person.
This Privacy Policy describes how we handle and protect your personal data in
connection with TRG's business activities, like events, and client services,
and on websites, applications, and communications that post a link to this
Privacy Policy (collectively, “the Sites”), in our capacity as data
controllers. Please see our Terms of Use for more information about our
online terms and policies in general.
Information we collect
TRG collects personal data
in the course of its business activities, including in connection with some
client services. We also collect personal data on certain areas of the Sites
when creating a user profile, registering for newsletters and alerts, participating
in our activities through our websites, signing up for events, and/or participating
in public user posting areas (such as bulletin boards, discussion forums and
surveys). The personal data collected varies and may include information that
you provide, such as your name, business mailing address, e-mail address, and
mobile telephone number.
We may also automatically
collect information about the devices you use to interact with our Sites. The
information we automatically collect may include IP address, device identifier,
web browser, and browsing information collected through cookies, web beacons,
pixels, clear gifs, and other similar technologies (collectively “Cookies and
Other Tracking Technologies”) on our Sites. We may also automatically collect
information about how you use the Sites, such as what you have searched for and
viewed on the Sites. The information automatically collected may be associated
with a unique identifier as well as with any other personal data you have
provided.
TRG may also collect
personal data about you from third parties in the course of its business
activities including in connection with some client services. This includes
demographic, professional, and other information that is publicly available
online, including information you choose to make public through social media
platforms and other public online forums. We may combine this data with the existing
information we have about you or use it independently, for the purposes of our
benchmarking and data analytics activities (e.g., analysis of recruiting
practices across an industry, detecting fraud patterns in connection with
financial transactions, foot traffic in retail environments). We will always
seek to confirm that the third-party has provided transparent information about
its use of this data, including its disclosure to third parties like TRG, in
compliance with applicable law.
Use of information
TRG uses your personal data
to fulfill your requests for information, process your requests to participate
in events, personalize content that you view or receive on the Sites, evaluate
and improve our services, distribute newsletters and alerts to you, analyze the
Sites’ performance and functioning, publish your comments, prevent fraud,
enforce our terms of use, comply with all applicable laws and corporate
reporting obligations, enforce TRG’s agreements, and accomplish other purposes
you may initiate or request. In some situations, the collection of personal
data may be required for the operation of the Sites, or we may use it in the
course of our business activities, including in connection with some client
services, for example, to provide certain services or products such as our
benchmarking products. We may combine and/or analyze personal data to evaluate
and offer content and services most relevant to you. We may keep any of your
personal data on file and use it to contact you.
TRG and its service
providers may use first and third-party Cookies and Other Tracking
Technologies, including web beacons, to manage our Sites and our services and
collect analytics about how you use them. TRG and its service providers may
collect information about whether you open or click any links in the knowledge,
research or event communications that we send to you. The information provided
throughout this Privacy Policy about cookies also applies to these other
tracking technologies.
Our Sites do not track you
by collecting personal data about your online activities over time and across third-party
websites or online services. Accordingly, we do not alter our data collection
and use practices in response to “do not track” signals transmitted from web
browsers.
Use of information collected
via mobile devices
In connection with our
mobile applications, TRG may use third-party service providers to analyze user
activity to fix errors, monitor usage, and improve the performance of the
mobile applications. For example, TRG receives reports on some of our mobile
applications’ aggregate usage and browsing patterns, including information
about the type of device used, articles accessed, and other events occurring
within our apps. TRG also receives reports on certain errors occurring within
mobile applications.
The legal basis by which we
process your personal data
Our processing of your
personal data for the purposes mentioned above is based:
· in part, on our legitimate interests in
promoting and protecting TRG, building and maintaining relationships, and
providing our services;
· in part, on your consent, for example,
if you create a user profile, or register for our newsletters or alerts, or for
business purposes that support web operations such as understanding and
enhancing the quality of your experience on our web-sites;
· in part, to comply with the law, when certain
information is necessary to satisfy our legal or regulatory obligations.
Disclosure of personal data:
data recipients and data transfers
Personal data collected in
the course of TRG business activities, including in connection with some client
services, as well as on the Sites may be transferred from time to time to TRG
subsidiaries and affiliates and their personnel, as well as to our third-party
service providers. Additionally, the Sites may be viewed and hosted by TRG and
our third-party service providers. Where required by law, we have put in place
legal mechanisms designed to ensure adequate data protection of your personal
data that is processed by TRG subsidiaries, affiliates, and third-party service
providers, including the transfer of your personal data. By using any of the
Sites and providing information on any of them, you voluntarily consent to such
transfer and hosting of such information.
TRG will not intentionally
disclose or transfer (and will take reasonable steps to prevent the
unauthorized or accidental disclosure of) your personal data to third parties
without your consent or as otherwise permitted by law, whether for such third
parties’ own marketing purposes or otherwise, except as follows. TRG may
provide access to your personal data to third-party service providers engaged
by TRG to provide services related to the Sites as well as related to TRG’s
business activities, including in connection with some client services, in the
manner agreed upon in our client services agreements. We maintain processes
designed to ensure that any processing of personal data by third-party service
providers is consistent with this Privacy Policy and protects the
confidentiality, availability, and integrity of your personal data.
We also may share your
personal data with third-party service providers who perform services and
functions on our behalf to support our interactions with you, including, for
example, processing orders, notifications, administering surveys or contests,
or communicating with you.
In addition, we may
disclose information about you:
· If we are required to do so by law or
legal process;
· To law enforcement authorities or other
government officials;
· When we believe disclosure is necessary
or appropriate to prevent physical harm or financial loss or in connection with
an investigation of suspected or actual illegal activity;
· If disclosure is necessary to protect
the vital interests of a person;
· To enforce our Terms of Use;
· To protect our property, services and
legal rights;
· To prevent fraud against TRG, our
subsidiaries, affiliates and/or business partners;
· To support auditing, compliance, and
corporate governance functions; or
· To comply with any and all applicable
laws.
In addition, we may
disclose or transfer your personal data in the event of a re-organization,
merger, sale, joint venture, assignment, or other transfer or disposition of
all or any portion of our business.
User forums
You should be aware that
whenever you publicly disclose information online, that information could be
collected and used by others. TRG is not responsible for any action or policies
of any third parties who collect information that users publicly disclose in
any such forums on the Sites.
Link to third-party sites
TRG may provide links to third-party
websites or information as a service to our users. If you use these links, you
will leave the Sites. Such links do not constitute or imply an endorsement,
sponsorship, or recommendation by TRG of the third-party, the third-party
website, or the information contained therein, and TRG shall not be responsible
or liable for your use thereof. Such use shall be subject to the terms of use
and privacy policies applicable to those sites.
Social Networking
The Sites may allow you to
sign into and associate your social network accounts including, but not limited
to, Twitter, LinkedIn, Facebook, and YouTube, with TRG. The Sites also may
allow you to log in to a TRG account using certain social network account
credentials.
By associating your social
network account with TRG or logging in to a TRG account using your social
network account credentials, you give us permission to access information that
you have made available in your public profile for that social network account.
The information available in your public profile varies based on the social
network and your settings, but may include your email address, real name,
profile picture, gender, and location. We may use the information we receive
from your social network account in accordance with the social network’s terms
of use and this Privacy Policy. Please refer to the privacy settings in your
social network account for information about what data is shared with TRG and
other connected applications and to manage the data that is shared through your
account, including information about your activities using our Sites.
If you would like to
disconnect a social media account from us, refer to the settings of that social
network account and its provider.
Security
TRG has implemented
generally accepted standards of technology and operational security to protect
personal data from loss, misuse, alteration, or destruction. Only authorized TRG
personnel and third-party service providers are provided access to personal
data, and these employees and service providers are required to treat this
information as confidential. Despite these precautions however, TRG cannot
guarantee that unauthorized persons will not obtain access to your personal
data.
Data retention
TRG retains personal data,
as necessary, for the duration of the relevant business relationship.
We may also retain personal
data for longer than the duration of the business relationship should we need
to retain it to protect ourselves against legal claims, use it for analysis or
historical record-keeping, or comply with our information management policies
and schedules. If you request that we delete your personal data, TRG will make
reasonable attempts to delete all instances of the information in its entirety.
For requests for access, corrections, or deletion, please refer to the “Your
Rights” section of this Privacy Policy.
Children
The Sites are not designed
for or directed at children 16 years of age or younger, and TRG does not
intentionally collect or maintain personal data about anyone under this age.
Your rights
Where granted by applicable
law, you may have the right to request access to the personal data that we have
collected about you for the purposes of reviewing, modifying, or requesting
deletion of the data. You may also have the right to request a copy of the
personal data that we have collected about you and to have any inaccuracies in
that data corrected. In certain circumstances, you may also request that we
cease processing your personal data.
If you would like to make a
request to access, review, or correct the personal data we have collected about
you, or to discuss how we process your personal data, please contact us. To
help protect your privacy and security, we will take reasonable steps to verify
your identity, such as requiring a password and user ID, before granting access
to your personal data. We will make reasonable attempts to promptly
investigate, comply with, or otherwise respond to your requests as may be
required by applicable law. Different laws may prevent us from providing access
to your personal data or otherwise fully complying with your request depending
upon the circumstances and the request, such as for example, where producing
your information may reveal the identity of someone else. We reserve the right
to charge an appropriate fee for complying with your request where allowed by
applicable law, and/or deny your requests where they may be manifestly
unfounded, and/or excessive, or otherwise objectionable or unwarranted under
applicable law.
In addition, and where
granted by local law, you have the legal right to lodge a complaint with a
competent data protection authority.
Unsubscribe
If you have registered for TRG
newsletter or alerts, or you receive invitations to survey or events from TRG
and you prefer not to receive future email communications from us, please “reply”
to the communication with “unsubscribe” in the subject line.
Your California privacy rights
If you are a California
resident under the age of 18, and a registered user of any of the Sites where
this Privacy Policy is posted, California Business and Professions Code Section
22581 permits you to request and obtain removal of content or information you
have publicly posted. To make such a request, please send an email with a
detailed description of the specific content or information to CSS@GetDocsNow.com Please be aware that such a request
does not ensure complete or comprehensive removal of the content or information
you have posted and that there may be circumstances in which the law does not
require or allow removal even if requested.
As required by the
California Consumer Privacy Act (CCPA), this Privacy Policy describes the
categories of personal data collected, processed, and disclosed by TRG, the
categories of sources for that data, and the business or commercial purposes
for which that data is collected, processed, and disclosed.
In addition, under
California law, you may have the right (up to two times in any 12-month period)
to request more information about TRG’s collection, use, disclosure, and sale
of personal data about you including:
· The categories of personal data about
you that we have collected in the preceding 12 months and the categories of
sources of that information,
· The categories of sources from which we
have collected that information in the preceding 12 months,
· The commercial or business reason(s) we
have collected, used, disclosed, or sold that information, and
· The categories of third parties to whom
we have disclosed or sold that information in the preceding 12 months.
· In addition, upon receipt of a
verifiable request from you establishing your identity, you may have the right
to know about the specific pieces of personal data that we have collected about
you and/or shared with third parties in the preceding 12 months.
You may also have the right
to request deletion of personal data about you that we have collected or
maintained, which we will honor subject to certain limitations set forth in
California law.
If you are a California
consumer and you or your authorized agent would like to exercise your privacy
rights, please contact us at CSS@GetDocsNow.com. We will contact you by phone
to process your request. We require you to provide certain personal data about yourself
in order to verify your identity in accordance with requirements under CCPA.
This may include your first and last name, email address, physical address,
telephone number, and information about your relationship with us or other
information needed to verify your identity. TRG will not discriminate against
you based on your exercise of any of these rights.
Consent; changes to Privacy
Policy
By using the Sites, you
consent to the collection, use, and storage of your personal data by us in the
manner described in this Privacy Policy and elsewhere on the Sites. We reserve
the right to make changes to this Privacy Policy from time to time. We will
alert you to any such changes by updating this Privacy Policy. If we make
material changes to this Privacy Policy that increase our rights to use
personal data that we have previously collected about you, we will obtain your
consent either through an email to your registered email address or by
prominently posting information about the changes on our Sites.
Contact us
If you have any questions
about our Privacy Policy please contact us at:
GetDocsNow.com
205 N. Stephanie St, D-120
Henderson, NV 89002
+1 702-353-2939
CSS@GetDocsNow.com