Our Privacy Policy

This is the Privacy Policy (“Privacy Policy”) of Rejoiner Inc. (“Rejoiner”, “our”, “us” or “we”). Rejoiner is committed to maintaining privacy protections for its users. Our Privacy Policy was developed as an extension of our commitment to integrity in dealing with our users and clients.

1. INTRODUCTION

1.1 Part A – Website Services

Part A of this Privacy Policy is designed to assist you in understanding how we collect, use and store the Personal Data you provide to us and the data we collect in connection with your use of our website (Rejoiner.com; the “Website”) (the “Website Services”). Please read this policy carefully so that you understand your rights in relation to your Personal Data, and how we will collect, use and process your Personal Data. If you do not agree with this Privacy Policy in general or any part of it, you should not use the Website Services.

Individuals in the EU should refer to paragraph 7 (Rights for Users in the EU) for further details regarding their rights in relation to this data.

1.2 Part B – Marketing Services

Part B of this privacy policy describes how we our process Personal Data as a service provider to our customers when they use our online website user tracking platform and related marketing services (the “Marketing Services”).

1.3 Definitions

Personal Data” includes any information relating to an identified or identifiable natural person, including information that can be linked to a specific individual, such as a name and/or your business name, address, telephone number, email address, and other information which you submit to us in relation to the Services and preferences you submit and preferences that are generated based on the data you submit and your use of and interactions with the Website.

Services” means the Website Services and the Marketing Services.

1.4 Changes to Our Privacy Policy

Please read the Terms of Service and this Privacy Policy carefully. Rejoiner reserves the right to change this Privacy Policy and our Terms of Use at any time. We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our Website. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Website and this privacy page for updates. The effective date of the latest version of the Privacy Policy will appear on this page.

1.5 Contact Us

If you wish to access, delete or correct you information, please send us an email to support@rejoiner.com. If you are in the EU please see paragraph 7 (Rights for Users in the EU) for more detail about your rights.

If you have any questions regarding this Privacy Policy or the practices of this Website, please contact us by sending an email to support@rejoiner.com.


PART A
WEBSITE SERVICES

For the purposes of the General Data Protection Regulation (the “GDPR”), we are a company established in Delaware with a registered office at 26 Washington Square, Suite 7, Newport, RI 02840, USA and we are the data controller in respect of the Personal Data (as defined above) processed in connection with the Website Services. Our data protection officer can be contacted at gdpr@rejoiner.com.

2. INFORMATION WE COLLECT AND HOW WE USE IT

2.1 Information you give us

You may choose to provide us with Personal Data in connection with your use of the Website, such as your email address, name, your business name, website address, login details and frequency via the Contact Us function, if you request information on your Return on Investment using our ROI calculator].

As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our products and organisation, we will use your information to:

  • communicate and be responsive to you;
  • provide you with user support;
  • enforce our terms and conditions and policies;
  • administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, and statistical and survey purposes, and ensure the proper functioning of the Website;
  • if you have opted in to marketing, communicate with you about products, services, promotions, events and other news and information we think will be of interest to you;
  • provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information).

For GDPR purposes, users in the EU have rights in relation to this Personal Data. Please see paragraph 7 (Rights for Users in the European Union) for more details.

2.2 Technical Usage Information

We collect certain technical information, such as usage data, referring/exit pages and URLs, your Internet service provider, the type of browser you use, your operating system, platform types, the device from which you connected to the Website, the time and date of access, the Website pages viewed, time spent at our Website, the websites visited just before and just after our Website, and other information that does not personally identify you relating to your use of the Website including by using cookies (see below), as it is in our legitimate interest to improve the quality and performance of the Website. For GDPR purposes, users in the EU have rights in relation to this Personal Data. Please see paragraph 7 (Rights for Users in the European Union) for more details.

2.3 Cookies Policy

We use cookies, pixel tags, web beacons, and similar files or technologies to collect and store the information we automatically collect about your computer, device, and use of the Website. You can find out more about cookies and how to control them in the information below.

If you do not accept the use of these cookies, please disable them using the instructions in this cookie policy, by following the 'opt-out' links provided below or by changing your browser settings so that cookies from the Website cannot be placed on your computer or mobile device.

(a) What is a cookie?

Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a certain webpage. Cookies are then sent back to the originating webpage on each subsequent visit, or to another webpage that recognizes that cookie. Cookies are widely used in order to make websites work, or to work more efficiently, as well as to provide information to the owners of the website.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies may tell us, for example, whether you have visited the website before or whether you are a new visitor. They can also help to ensure that adverts you see online are more relevant to you and your interests.

There are two broad categories of cookies:

  • First party cookies: served directly by us to your computer or mobile device.
  • Third party cookies: which are served by a third party on our behalf. We use third party cookies for functionality, and performance / analytics purposes.

Cookies can remain on your computer or mobile device for different periods of time. Some cookies are 'session cookies', meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are 'permanent cookies', meaning that they survive after your browser is closed. They can be used by the Website to recognise your computer when you open your browser and browse the Internet again.

(b) How do we use cookies?

We use cookies to:

  • track traffic flow and patterns of travel in connection with the Website;
  • understand the total number of visitors to our Website on an ongoing basis and the types of internet browsers (e.g. Firefox, Chrome) and operating systems (e.g. Windows or Mac OS) used by our visitors;
  • monitor the performance of the Website and to continually improve it; and
  • customize and enhance your online experience.
  • to serve advertisements most relevant to you across your different devices on websites and mobile applications.
(c) What types of cookies do we use?

The types of cookies used by us and our partners in connection with the Website can be classified into one of five categories, namely 'essential Website cookies', 'functionality cookies', 'analytics and performance cookies', 'advertising cookies', and 'social media cookies'. We've set out some further information about each category, and the purposes of the cookies we and third parties set in the following table.

Type of cookie What it does How to block
Cookies necessary for essential Website purposes These cookies are essential to provide you with the Website Services and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like secure login accounts, would not be possible. Please see the instructions set out in 'How to control or delete cookies' below.
Functionality Cookies Functionality cookies record information about choices you've made and allow us to tailor the Website to you. These cookies mean that when you continue to use or come back to the Website, we can provide you with Website Services as you have asked for them to be provided. For example, these cookies allow us to:
  • Functionality cookies record information about choices you've made and allow us to tailor the Website to you. These cookies mean that when you continue to use or come back to the Website, we can provide you with Website Services as you have asked for them to be provided. For example, these cookies allow us to:
  • Save your location preference if you have set your location on your homepage, if applicable, in order to receive a local weather forecast;
  • Remember settings you have applied, such as layout, text size, preferences, and colors;
  • Show you when you are logged in; and
  • Store accessibility options.
Please see the instructions set out in 'How to control or delete cookies' below.
Performance / Analytics Cookies We use performance/analytics cookies to analyse how the Website is accessed, used, or is performing in order to provide you with a better user experience and to maintain, operate and continually improve the Website. For example, these cookies allow us to:
  • Better understand our Website visitors so that we can improve how we present our content;
  • Test different design ideas for particular pages, such as our homepage;
  • Collect information about Website visitors such as where they are located and what browsers they are using;
  • Determine the number of unique users of the Website;
  • Improve the Website by measuring any errors that occur; and
  • Conduct research and diagnostics to improve product offerings.
Please also see the instructions set out in 'How to control or delete cookies' below.
Advertising and Tracking Cookies We allow third party companies, including advertising companies (e.g. Google Remarketing), to place cookies on our Website. These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet, e.g. you may see an advertisement for Rejoiner on another site you visit after visiting the Rejoiner website. These cookies are anonymous -- they store information about the content you are browsing, but not about who you are.
Cookies also allow us and third parties to know whether you've seen an ad or a type of ad, and how long it has been since you've last seen it. This information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads.
All the ad companies or networks that we work with have their own privacy policies and offer a mechanism for users to opt out tracking and behavioral targeting available through the ad itself or through the opt out mechanisms listed in the 'How to control or delete cookies' section below.
Social Media Cookies On some pages of our Website, third parties that provide applications through our Website may set their own anonymous cookies in order to track the success of their applications or customize applications for you. For example, when you share an article using a social media sharing button on our Website (e.g., Facebook, Twitter, LinkedIn), the social network that has created the button will record that you have done this. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us. Some pages of our Website may also contain embedded content, such as video content from YouTube, and these sites may set their own cookies. Please see the instructions set out in 'How to control or delete cookies' below.
Google Analytics Cookies We use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page.
Attribution Cookies We use Attribution, a web analytics tool, to help us measure the effectiveness of our marketing efforts across various channels. Attribution provides insight into which sources of traffic are the most effective and generating leads for the Services. Attribution ties individual lead email addresses back to the referral source that drove the traffic. Please see the instructions set out in 'How to control or delete cookies' below.
Crazy Egg Cookies We use Crazy Egg, a web analytics tool, to help us understand how users are engaging with pages on our website. Crazy Egg aggregates scroll distance and click data anonymously, to show us how users are engaging with the content on our website. Crazy Egg provides aggregated ‘heatmap’ and ‘click-target’ reports for each individual page on the Rejoiner website. You can opt out of Crazy Egg without affecting how you visit our site – for more information on opting out please visit this page.

(d) How to control or delete cookies

You have the right to choose whether or not to accept cookies and we have explained how you can exercise this right below. However, please note that if you choose to refuse cookies you may not be able to use the full functionality of our Website.

Most browsers allow you to change your cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.

If you only want to limit third party advertising cookies, you can turn such cookies off by visiting the following links:

Please bear in mind that there are many more companies listed on these sites than those that drop cookies via the Website.

(e) Need More Information?

If you would like to find out more about cookies and their use on the Internet, you may find the following links useful:

(f) Cookies that have been set in the past

If you have disabled one or more Cookies, we may still use information collected from cookies prior to your disabled preference being set, however, we will stop using the disabled cookie to collect any further information. Many web browsers support Do Not Track technology. While we strive to offer you choices when you use our website and services, we do not currently honor web browser Do Not Track signals.


3. WHERE DO WE STORE YOUR PERSONAL DATA?

This Website is hosted and operated in the United States. Please note that the Personal Data you submit to us in order to use the Website Services and the Website in accordance with the terms and conditions will be transferred to and stored in the United States to be processed by us so we can provide the Website Services to you as set forth in the Terms of Service.

You acknowledge and agree that we may store and process your Personal Data in the United States. Please note that the level of legal protection provided in the United States or other non-European countries in which you use the Services may not be as stringent as that under European Union privacy standards or the privacy laws of some other countries, possibly including your home jurisdiction.

Rejoiner complies with the US Department of Commerce's EU-US Privacy Shield and has certified that we adhere to the EU-US Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability to enable the transfer of Personal Data from the EU. See Part 3 for further details.

4. WHO HAS ACCESS TO YOUR PERSONAL DATA?

Rejoiner will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, including to meet national security or law enforcement requirements, or if we have a good faith belief that such use is reasonably necessary to:

  • comply with a legal obligation, process or request;
  • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law.

Rejoiner will also disclose your information to third parties:

  • in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; or
  • if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.

For the purposes of the GDPR, please refer to Schedule 1 (Recipients of Data) for further details on third party recipients of your data, their location, and reasons for such transfer/processing.

5. NO USE OF OUR WEBSITE BY PERSONS UNDER 13

The Website is not intended for use by anyone under 18, except with the explicit permission and under the supervision of a parent or guardian who accepts full legal responsibility for the minor's use.

6. HOW WE PROTECT INFORMATION

We implement security measures designed to protect your information from unauthorized access, disclosure or accidental loss or destruction. We have implemented technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using visiting our Website and using our Services, you acknowledge that you understand and agree to assume these risks. Communications you may have with us via email or mail may not be secure unless we advise you that security measures are in place prior to your sending information. Therefore, if you choose to communicate with us through these means, you are assuming the risk of doing so and we request that you do not send or post sensitive information through these means.

7. YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL DATA

You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication, the recipient can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the Settings section of the Website, we may continue to send you administrative emails including, for example, in order to effectively provide you with the Services and periodic updates to our Privacy Policy.

8. RIGHTS FOR USERS IN THE EUROPEAN UNION

For users of the Website Services in the European Union, the following provisions will apply.

8.1 Your rights.

In certain circumstances you have rights in relation to the Personal Data we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights. To exercise any of your rights, please email gdpr@rejoiner.com. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

Access and Portability: You have the right to know whether we process Personal Data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.

Portability: You have the right to receive a subset of the Personal Data you provide us if we process it on the bases of our contract with you or with your consent in a .csv file and a right to request that we transfer such Personal Data to another party. If you wish for us to transfer the Personal Data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party.

Correction: You have the right to require us to correct any Personal Data held about you that is inaccurate and have incomplete data completed.

Erasure: You may request that we erase the Personal Data we hold about you in the following circumstances: where you believe it is no longer necessary for us to hold the Personal Data, we are processing it on the basis of your consent and you wish to withdraw your consent, we are processing your data on the basis of our legitimate interest and you object to such processing, you no longer wish us to use your data to send you marketing or you believe we are unlawfully processing your data.). Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure.

Restriction of Processing to Storage Only: You have a right to require us to stop processing the Personal Data we hold about you other than for storage purposes in the following circumstances: you believe the Personal Data is not accurate for the period it takes for us to verify whether the data is accurate, we wish to erase the Personal Data as the processing we are doing is unlawful but you want us to simply restrict the use of that data; we no longer need the Personal Data for the purposes of the processing but you require us to retain the data for the establishment, exercise or defence of legal claims; and you have objected to us processing Personal Data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Personal Data whilst we determine whether there is an overriding interest in us retaining such Personal Data.

Objection: You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.

(a) Withdrawal of Consent

Where you have provided your consent to us processing your Personal Data, you can withdraw your consent at any time by clicking on this opt-out link.

(b) Objection to Marketing

At any time you have the right to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.

(c) Complaints

In the event that you wish to make a complaint about how we process your Personal Data, please contact us in the first instance at gdpr@rejoiner.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

9. LINKS TO OTHER WEBSITES

As part of the Website Services, we may provide links to or compatibility with other websites or applications. Some of these sites may be co-branded with the Rejoiner name or logo. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us in relation to the Website Services. Therefore, this Privacy Policy does not apply to your use of a third party website accessed by selecting a link on our Website or via our Website Services. The privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.


PART B
MARKETING SERVICES

10. REJOINER CLIENTS

10.1

If you engage Rejoiner to provide any of our online website user tracking platform and related marketing services (the “Marketing Services”), Rejoiner will be a data processor of such data. Recipients of the Marketing Services (“Client”) and Rejoiner will enter into a separate agreement that will, among other things, govern the use of all of the information and data collected and maintained by Rejoiner in connection with the operation of the service. Any agreement (including any data processing addendum) between Client and Rejoiner will take precedence over any conflicting provision in this Privacy Policy. This agreement applies to Client’s use of our customer portal, and any data provided or generated by creating a Client user account and Client use of the customer portal.

10.2

Information provided by Client. Client may provide information through the Website such as name, email address, eCommerce platform, website address, phone number, payment information (including billing addresses), usage information (including login location and frequency).

Client may also provide Client customer data in the course of Client’s use of the Marketing Services including:

 
  • website browsing data (such as pages accessed, time on page, page view frequency);
  • geolocation data;
  • eCommerce event data (such as cart activity);
  • purchase data (transaction total, purchased items, promotion usage);
  • email engagement data (email opens, email clicks, browser usage, device usage);
  • demographic data (first name, last name, age, gender, language, currency, time zone).
10.3

We collect and process this data in order to provide the Marketing Services to the Client.

11. CUSTOMERS OF REJOINER CLIENTS

If you receive any goods or services from a Client, Client may contact you for marketing purposes using our platform and/or information provided by us in connection with the Marketing Services. Please refer to the relevant Client privacy policy for provisions governing such communications and any related processing of Personal Data by Client.

12. CALIFORNIA PRIVACY RIGHTS

California law permits visitors who are California residents to request certain information regarding our disclosure of personally identifiable information to third parties for their direct marketing purposes. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To make such a request, please contact gdpr@rejoiner.com.


SCHEDULE 1
RECIPIENTS OF DATA

Categories of recipients include:

  • third party payment processors located in the United States (e.g. Stripe) and which store your Personal Data in the United States to collect payment for Marketing Services we provide to you;
  • third party service providers located in the United States (e.g. Mailgun) and which store your Personal Data in the United States who send communications to you on behalf of Rejoiner;
  • cloud storage provides located in the United States (e.g. Amazon Web Services and IBM) and which store your Personal Data in the United States, to store the Personal Data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;
  • third party service providers located in the United States (e.g. Sentry) which store your Personal Data in the United States to provide error-logging services for the Services to assist in troubleshooting and maintenance of Rejoiner infrastructure.

Last Updated: This Privacy Policy was last updated on May 24th, 2018