RPM Software

This California Consumer Privacy Statement (“Statement”) supplements the RPM Software, LLC Privacy Policy. This Statement applies solely to personal information collected about California consumers, such as our customers, website visitors, attendees of our webinars, trainings and/or other events, our business partners, and our job applicants. This Statement does not apply to our personnel.

This California Consumer Privacy Statement uses certain terms that have meanings given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).

Notice of Collection and Use of Personal Information 

We may collect (and may have collected during the 12-month period prior to the Last Updated date) the following categories of personal information about you: 

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as device identifiers; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number; unique pseudonym; user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, login credentials, Social Security number, driver’s license number, passport number and other similar identifiers.
  
  
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, credit card number, debit card number, bank account number and other financial information, state identification card number, medical information, and education information.
  
  
• Protected Classifications: characteristics of protected classifications under California or federal law, such as gender, race, age, sex, national origin, medical condition, disability, citizenship status, and military and veteran status.
  
  
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
  
  
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history and information regarding your interaction with websites, applications or advertisements.
  
  
• Geolocation Data
  
  
• Sensory Information: audio, electronic, visual, and similar information
   
• Employment Information: professional or employment-related information, such as business contact information, résumé information, occupation details, education details, certifications and professional associations, previous employment details, pre-employment screening and background check information, including criminal records information.
  
  
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
  
  
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  
  

We may use (and may have used during the 12-month period prior to the Last Updated date) the categories of personal information listed above for the purposes described in the RPM Software, LLC Privacy Policy and for the following business purposes as described in the CCPA: 

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
  
  
• Providing advertising and marketing services to you, except for cross-context behavioral advertising;
  
  
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
  
  
• Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us;
  
  
• Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes;
  
  
• Debugging to identify and repair errors that impair existing intended functionality;
  
  
• Undertaking internal research for technological development and demonstration;
  
  
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;
  
  
• Conduct our training, webinars, and other events;
  
  
• Administer contests, surveys, sweepstakes or other promotions;  
  
  
• Managing career opportunities with us; and
  
  
• Managing our relationships with current or prospective partners, corporate customers and vendors and other business partner personnel.
  
  

We do not collect or process sensitive personal information with the purpose of inferring characteristics about consumers. 

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in the RPM Software, LLC Privacy Policy and this Statement, or any other notice provided at the time of collection, taking into account our legal obligations and our records retention requirements pursuant to our Records Management Policy and Schedule.

Sources of Personal Information

During the 12-month period prior to the Last Updated date, we may have obtained personal information about you from the following categories of sources: 

• Directly from you, such as when you complete our forms or surveys, attend our events (including any webinars or trainings), or otherwise contact us
  
  
• From your devices, such as when you interact with our website, products, and other online services
  
  
• Vendors who provide services on our behalf
  
  
• Other individuals, such as referrals
   
• Our business partners
  
  
• Data brokers, such as background check services
  
  
• Recruiting and talent agencies
  
  
• Job references, such as your employers
  
  
• Data analytics providers
  
  
• Internet service providers
  
  
• Operating systems and platforms
  
  
• Government entities
  
  

Sale or Sharing of Personal Information

We do not sell your personal information or share your personal information for cross-context behavioral advertising purposes.

Disclosure of Personal Information

During the 12-month period prior to the Last Updated date, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date, we may have disclosed personal information about you to government entities (e.g., in response to law enforcement requests) and third parties in connection with corporate transactions (e.g., mergers, acquisitions, joint venture, reorganization, divestitures, dissolution or liquidation).

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the categories of personal information we have collected about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
  
  
• Correction: You have the right to request that we correct the personal information we maintain about you if that information is inaccurate.
  
  
• Deletion: You have the right to request that we delete certain personal information we have collected from you.
  
  

How to Submit a Request

To submit an access, correction, or deletion request, please contact us toll-free at 1-800-944-2432 or email us at [email protected] with “Personal Information Request” in the subject line and provide full details about your request, including the type of request you are making, that you are making a request relating to RPM, and your contact information. To submit a request as an authorized agent on behalf of a consumer, please contact us toll-free at 1-800-944-2432 or email us at [email protected] with the subject line Authorized Agent Request and provide full details about the request.

Verifying Requests 

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an individual online account with us, we may verify your identity by requiring you to sign into your account. If you do not have an individual online account with us, we may require you to provide certain information to verify your identity, such as name, email address, phone number, company name, and/or an indication of your prior contact with us, depending on the information we have about you. In addition, if you do not have an individual online account and you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

If you designate an authorized agent to make a request on your behalf, depending on whether you have an individual online account with us, we may require that you verify your identity as set forth above. We also may require you to provide the authorized agent a written confirmation that you have authorized the agent to act on your behalf and the scope of such authorization.

Additional Information

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. For questions or concerns about our privacy policies and practices, please contact us as described in the “How to Contact Us” section of the RPM Software, LLC Privacy Policy.