PRIVACY POLICY
last updated November 15, 2020

RINO Investment LLC (“RINO INVEST”) takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 4.

To the extent we provide you with notice of different or additional privacy policies, those policies will govern such interactions.

1. The Basics

A. About Us

www.rinoinvest.co is a website (“Site”) operated by Rino Investment LLC, a limited liability company organized under the laws of the state of Georgia and headquartered in the State of  ________ __________ in the United States (“we,” “us,” “our,” and ” RINO INVEST”).

B. Key Terms

In this privacy policy, these terms have the following meanings:

“Affiliate” means an entity that directly or indirectly Controls, is Controlled by or is under common Control with an entity.

“Control” means an ownership, voting or similar interest representing fifty percent (50%) or more of the total interests then outstanding of the entity in question. The term “Controlled” shall be construed accordingly.

“Member” means any person or entity that is registered with us to use the Service.

“Mobile App(s)” means any one or all of the RINO INVEST applications available for Members to use on their mobile devices.

“Personal Information” means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.

“Service” has the meaning given to it in our Terms of Service.

“Visitor” means, depending on the context, any person who visits our Site, or otherwise engages with us at our events or in connection with our marketing activities.

“you” and “your” means, depending on the context, either a Member, or a Visitor.

2. Privacy for Members

This section applies to the Personal Information we collect and process from a Member or potential Member through the provision of the Service. If you are not a Member, the Visitors or Contacts section of this policy may be more applicable to you and your data. In this section, “you” and “your” refer to Members and potential Members.

A. Information We Collect

The Personal Information that we collect depends on the context of your interactions with RINO INVEST, your RINO INVEST account settings, the products and features you use, your location, and applicable law. However, the Personal Information we collect broadly falls into the following categories:

(i) Information you provide to us: You (or your organization) may provide certain Personal Information to us when you sign up for a RINO INVEST account and use the Service, consult with our customer service team, send us an email, or communicate with us in any other way.

This information may include:

Business contact information (such as your name, job title, organization, location, phone number, email address, and country);

Marketing information (such as your contact preferences);

Account log-in credentials (such as your email address or username and password when you sign up for an account with us);

Troubleshooting and support data (which is data you provide or we otherwise collect in connection with support queries we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help inquiry); and

Payment information (including your credit card numbers and associated identifiers and billing address).

(ii) Information we collect automatically: When you use the Service, we may automatically collect or receive certain information about your device and usage of the Service (collectively “Service Usage Data”). We use cookies and other tracking technologies to collect some of this information. If you are using our Mobile App, we may collect this information using our software development kits (“SDKs”) or APIs the first time the SDK or API is initiated on your Mobile App. For further information, please review the section below and our Cookie Statement available here.

Service Usage Data may include:

Device information: We collect information about the device and applications you use to access the Service, such as your IP address, your operating system, your browser ID, and other information about your system and connection. If you are using our Mobile App, we may also collect information about the cellular network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s name and unique device ID, and information about the features of our Mobile App that you accessed.

Log data: Our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP addresses and your activity in the Service (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take (for example, which features you used)), device event information (such as system activity, error reports (sometimes called ‘crash dumps’)), and hardware settings. We may also access metadata and other information associated with files that you upload into our Service.

Usage data: We collect usage data about you whenever you interact with our Service, which may include the dates and times you access the Service and your browsing activities (such as what portions of the Service you used). We also collect information regarding the performance of the Service, including metrics related to the deliverability of emails and other communications you send through the Service. If you are using our Mobile App, we may collect information about how often you use the Mobile App and other performance data. This information allows us to improve the content and operation of the Service, and facilitate research and analysis of the Service.

(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners.

Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other Personal Information we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and service.

B. Use of Personal Information

We may use the Personal Information we collect or receive through the Service (alone or in combination with other data we source) for the purposes and on the legal bases identified below:

To bill and collect money owed to us by you to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in accordance with our legitimate interests to operate and administer our Service. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see the “Our Security” section of this privacy policy.

To send you system alert messages in reliance on our legitimate interests in administering the Service and providing certain features. For example, we may inform you about temporary or permanent changes to our Service, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.

To communicate with you about your account and provide customer support to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our Service. For example, if you use our Mobile Apps, we may ask you if you want to receive push notifications about activity in your account. If you have opted in to these push notifications and no longer want to receive them, you may turn them off through your operating system.

To enforce compliance with our Standard Terms of Service and applicable law, and to protect the rights and safety of our Members in reliance on our legitimate interest to protect against misuse or abuse of our Service and to pursue remedies available. This may include developing tools and algorithms that help us prevent violations. For example, sometimes we review the content our Members send or display to ensure it complies with our Standard Terms of Service. To improve that process, we have software that helps us find content that may violate our Standard Terms of Use.

To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.

To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements in reliance on our legitimate interests.

To prosecute and defend a court, arbitration, or similar legal proceeding.

To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.

To provide, support and improve the Service to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Service and providing certain features. For example, this may include sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to you. When we share your Personal Information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws. For further information about how we share your information, refer to Section 4 below.

To provide suggestions to you and to provide tailored features within our Service that optimize and personalize your experience in reliance on our legitimate interests in administering the Service and providing certain features. This includes using data to recommend products or services that you may be interested in or that may be relevant to you. Some of these suggestions are generated through analysis of the data used in our data analytics projects, as described below.

To perform data analytics projects in reliance on our legitimate business interests in improving and enhancing our products and services for our Members. Our data analytics projects use data from RINO INVEST accounts to provide and improve the Service. We may use information like your purchase history, so we can make more informed predictions, decisions, and products for our Members. For example, we use data from RINO INVEST accounts to enable product recommendation, audience segmentation, and predicted demographics features for our Members. If you prefer not to have their data used for this purpose, you can alter the settings on your account (as described here)  opt out of data analytics projects at any time by emailing us atpersonaldatarequests@rinoinvest.co. As always, we take the privacy of Personal Information seriously, and will continue to implement appropriate safeguards to protect this Personal Information from misuse or unauthorized disclosure.

To personalize the Service, content and advertisements we serve to you in reliance on our legitimate interests in supporting our marketing activities and providing certain features within the Service. We may use your Personal Information to serve you specifically, such as to deliver marketing information, product recommendations and non-transactional communications (e.g., email, telemarketing calls, SMS, or push notifications) about us, in accordance with your marketing preferences and this privacy policy.

C. Cookies and Tracking Technologies

We and our third-party partners may use various technologies to collect and store Service Usage Data when you use our Service (as discussed above), and this may include using cookies and similar tracking technologies, such as pixels, web beacons, and if you use our Mobile Apps, through our SDKs deployed on your mobile device. For example, we use web beacons in the emails we send on your behalf, which enable us to track certain behavior, such as whether the email sent through the Service was delivered and opened and whether links within the email were clicked. Both web beacons and SDKs allow us to collect information such as the recipient’s IP address, browser, email client type and other similar data as further described above details. We use this information to enhance the effectiveness of our Service, and for other purposes described above. Reports are also available to us when we send email to you, so we may collect and review that information.

D. Your Data Protection Rights

To access; correct; update; port; delete; restrict; or object to our processing of your Personal Information.

You can manage your individual account and profile settings within the dashboard provided through your account, or you may contact us directly by emailing us at personaldatarequests@rinoinvest.co. You can also manage information about your Contacts within the dashboard provided through the RINO INVEST to assist you with responding to requests to access, correct, update, port or delete information that you receive from your Contacts. You can also contact us at any time to update your own marketing preferences (see Section 4. General Information, C. Your Choices and Opt-Outs below). RINO INVEST takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date.

Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.

We need certain Personal Information to create and maintain your account with us and you cannot ask us to delete; restrict or object to our processing of your Personal Information required for the maintenance of your account with us. You can however ask to close your account with us.

4. Privacy for Visitors

This section applies to Personal Information that we collect and process when you visit the Site, and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities. In this section, “you” and “your” refer to Visitors.

A. Information We Collect

(i) Information you provide to us on the Site or otherwise: Our Site offer various ways to contact us, such as through form submissions, email or phone, to inquire about our company and Service. For example, we may ask you to provide certain Personal Information when you express an interest in obtaining information about us or our Service, take part in surveys, subscribe to marketing, apply for a role with RINO INVEST, or otherwise contact us. We may also collect Personal Information from you in person when you attend our events or trade shows, via a phone call with one of our sales representatives. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we may keep copies of any such communications for our records.

The Personal Information we collect may include:

Business contact information (such as your name, phone number, email address and country);

Professional information (such as your job title, institution or company);

Nature of your communication;

Marketing information (such as your contact preferences); and

Any information you choose to provide to us when completing any ‘free text’ boxes in our forms.

(ii) Information we collect automatically through our Site: When you visit our Site or interact with our emails, we use cookies and similar technologies such as pixels or web beacons, alone or in conjunction with cookies, to collect certain information automatically from your browser or device.

The information we collect automatically includes:

Device information: such as your IP address, your browser, device information, unique device identifiers, mobile network information, request information (speed, frequency, the site from which you linked to us (“referring page”), the name of the website you choose to visit immediately after ours (called “exit page”), information about other websites you have recently visited and the web browser you used (software used to browse the internet) including its type and language)

Usage data: such as information about how you interact with our emails, our Site, and other websites (such as the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage).

B. Use of Personal Information

We may use the information we collect through our Site and in connection with our events and marketing activities (alone or in combination with other data we collect) for a range of reasons in reliance on our legitimate interests, including:

To provide, operate, optimize, and maintain our Site.

To send you marketing information, product recommendations and non-transactional communications (e.g., email, telemarketing calls, SMS, or push notifications) about us, in accordance with your marketing preferences, including information about our products, services, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent.

For recruitment purposes if you have applied for a role with RINO INVEST.

To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.

To manage the Site and system administration and security.

To manage event registrations and attendance, including sending related communications to you.

To improve the navigation and content of the Site.

To identify any server problems or other IT or network issues.

To process transactions and to set up online accounts.

To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.

To help us provide, improve and personalize our marketing activities.

To facilitate the security and continued proper functioning of the Site.

To carry out research and development to improve our Site, products and services.

To conduct marketing research, advertise to you, provide personalized information about us on and off our Site, and to provide other personalized content based on your activities and interests to the extent necessary for our legitimate interests in supporting our marketing activities or advertising our Service or instances where we seek your consent.

To carry out other legitimate business purposes, as well as other lawful purposes, such as data analysis, fraud monitoring and prevention, identifying usage trends and expanding our business activities in reliance on our legitimate interests.

To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our Site and Service, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, or responding to lawful requests.

C. Public Information and Third-Party Websites

Blog. We may have public blogs on the Site. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us here. If we are unable to remove your information, we will tell you why.

Social media platforms and widgets. The Site include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Site, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. We also maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

Links to third-party websites. The Site include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Contests and sweepstakes. We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on the Site or through social media (collectively, “Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include Personal Information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Service. We may share this information with our affiliates and other organizations or service providers in line with this privacy policy and the rules posted for our Promotions.

D. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising.

E. Other Data Protection Rights

Depending on the State in which you reside, you may have the following data protection rights:

To access; correct; update; port; delete; restrict or object to our processing of your Personal Information. You can exercise these rights by emailing personaldatarequests@rinoinvest.co.

Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. You can also contact us at any time to update your marketing preferences (see Section 4. General Information, C. Your Choices and Opt-Outs below).

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

5. General Information

A. How We Share Information

We may share and disclose your Personal Information with our Affiliates and to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, “you” and “your” refer to Members,  and Visitors unless otherwise indicated).

(i) Our service providers: Sometimes, we share your information with our third-party service providers working on our behalf for the purposes described in this privacy policy. For example, companies we’ve hired to help us provide and support our Service or assist in protecting and securing our systems and services and other business-related functions.

Other examples include analyzing data, hosting data, engaging technical support for our Service, processing payments, and delivering content.

We use YouTube’s API services in connection with our Service to provide certain features. As such, you acknowledge and agree that by signing up for an account and using the Service, you are also bound by Google’s Privacy Policy. In addition to the rights set forth in Section 2, you may manage your YouTube API data by visiting Google’s security settings page athttps://security.google.com/settings/security/permissions

In connection with our Service, we also use a third-party service provider, Twilio, Inc. We use Twilio’s API, which allows us to build features into our RINO INVEST application to enable us to communicate with our Members through texting and calling, and their “Authy” product, which we use for two-factor authentication for our application. If you are a Member, Twilio may need to collect and process certain Personal Information about you as a controller to provide such services. To learn more about Twilio’s privacy practices, please visit https://www.twilio.com/legal/privacy

(ii) Advertising partners: We may partner with third-party advertising networks, exchanges, and social media platforms (like Facebook) to display advertising on the Site or to manage and serve our advertising on other sites, and we may share Personal Information of Members and Visitors with them for this purpose. We and our third-party partners may use cookies and other similar tracking technologies, such as pixels and web beacons, to gather information about your activities on the Site and other sites in order to provide you with targeted advertising based on your browsing activities and interests.

(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.

(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Site.

(v) Any other person with your consent.

C. Your Choices and Opt-Outs

Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the “unsubscribe” link at the bottom of our marketing messages.

Also, all opt-out requests can be made by emailing us using the contact details provided in the “Questions and Concerns” section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Members cannot opt out of these messages unless you cancel your RINO INVEST account.

D. Our Security

We take appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us atprivacy@rinoinvest.co.

RINO INVEST accounts require a username and password to log in. Members must keep their username and password secure, and never disclose it to a third party. Because the information in a Member’s RINO INVEST account is private, account passwords are hashed, which means we cannot see a Member’s password. We cannot resend forgotten passwords either. We will only provide Members with instructions on how to reset them.

E. Retention of Data

We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to determine retention period:

Whether we have a legal or contractual need to retain the data.

Whether the data is necessary to provide our Service.

Whether our Members have the ability to access and delete the data within their RINO INVEST accounts.

Whether our Members would reasonably expect that we would retain the data until they remove it or until their RINO INVEST accounts are closed or terminated.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

F. California Privacy

The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which may include our Members with whom you have a relationship) disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.

When offering services to its Members, RINO INVEST acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our Members in order for us to provide the Service.

Consistent with California law, if you choose to exercise your applicable CCPA rights, we won’t charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.

G. Do not Track

Certain state laws require us to indicate whether we honor “Do Not Track” settings in your browser. RINO INVEST adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.

H. Changes to this Policy

We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Site. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Site.

I. Questions & Concerns

If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by postal mail or email at:

RINO INVEST

Attn. Privacy Officer
privacy@rinoinvest.co
Mailing Address:

HOURS OF OPERATION

© 2021 by RINO INVEST LLC