Privacy Policy: DAVID WHYTE AND MANY RIVERS CO LLC (“Many Rivers”)

Effective Date: June 2, 2021

This is the Privacy Notice for www.davidwhyte.com. The protection of your personal information and privacy are very important to us. Our websites carefully use and securely store all information that you enter on our sites. By visiting and using any and all website areas, features, and forms, you are accepting the practices described in this Privacy Notice. If you have any questions or concerns, please contact us at: [email protected].

INFORMATION WE MAY COLLECT AND WHAT WE MAY DO WITH IT 

Information You Provide

The types of information that Many Rivers collects directly from you or through your use of our web site and related services (“web site and services”) may include the following depending on how you interact with Many Rivers:

• Contact details, such as your name, email address, postal address, username, and telephone number;
• Internet Protocol (“IP”) addresses used to connect your computer to the Internet;
• Tracking codes such as cookies;
• Usernames and passwords;
• If Applicable, payment information, such as a credit or debit card number and related information;
• Comments and feedback you provide to Many Rivers (including through the Many Rivers web site) or to other users of the web site;
• Communication preferences;
• Search history;
• Information about your personal preferences, and interests; and
• Communications through our web site with other users of Many Rivers web site services.

Many Rivers may collect personal information about you in the following ways:

(1) directly from your verbal or written input (such as by consenting to receiving marketing emails or indirectly through third parties with whom we work closely (see below “Information We Receive From Other Sources”); or

(2) automatically through Many Rivers web site technologies including tracking online, such as by web cookies (which are small text files created by web sites that are stored on your computer); by collecting data from a browser or device for use on a different computer or device; or by using algorithms to analyze a variety of data such as records of online behavioral data, or location data.

In order to access certain content and to make use of additional functionality and features of Many Rivers web site and services, we may require you to register for a member account by completing and submitting a member registration form, which may request additional information. Your providing this information is your consent to the use of that information as provided in this Privacy Policy.

Information We May Receive from Other Sources

Many Rivers may receive information about you if you use the web site we operate or any other services we provide. We may at times work closely with third parties (including, for example, business partners and sub-contractors in technical, advertising networks; data and analytics providers; and similar organizations; and search information providers from whom Many Rivers may receive information about you.

Use of Your Information

Depending on how you interact with Many Rivers, Many Rivers may use your personal information in the performance of any contract or transaction we enter into with you, to comply with legal obligations, or where Many Rivers has a legitimate business interest. Legitimate business purposes include but are not limited to one or all of the following: providing direct marketing and assessing the effectiveness of promotions and advertising; modifying, improving or personalizing our services, products and communications; detecting fraud; investigating suspicious activity (e.g., violations of our Terms of Use) and otherwise keeping our web site safe and secure; and conducting data analytics. 

In addition, with your prior, explicit consent (where required), we may use your information in the following ways:

• To provide you with information about products and services that you request from us;
• To send you periodic services information from Many Rivers;
• To notify you about changes or updates to our web site or services;
• To provide, activate, and/or manage our services;
• For internal operations, including troubleshooting, data analysis, machine learning, testing, statistical, and survey purposes;
• To allow you to participate in interactive features of our service; and
• For any other purpose that we may notify you of from time to time.

Personal information will not be kept longer than is necessary for the purpose for which it was collected. This means that, unless information must be retained for legal or archival purposes, personal information will be securely destroyed, put beyond use or erased from Many Rivers systems when it is no longer required or, where applicable, following a request from you to destroy or erase your personal information.

Disclosure and Sharing of Your Information

Many Rivers will not disclose to or share your personal information with any unaffiliated third party except as follows:

• Where necessary in connection with services provided by third parties (i) who provide us with a wide range of office, administrative, information technology, web site and platform hosting, editing, production, payment, business management, analytics, content management, indexing, archiving, or marketing services; and (ii) who are required to comply with applicable privacy laws;
• Where third party has provided you with access to a Many Rivers product or service through an integration or access code, information may be shared regarding your engagement with the service or product, results of assessments taken and other information you input into the product or service;
• Where you participate in a program in which we partner with third parties, we may share your information with those third-party partners;
• Where Many Rivers is required to disclose personal information in response to lawful requests by public authorities and government agencies, including to meet national security or law enforcement requirements; to comply with a subpoena or other legal process; when we believe in good faith that disclosure is necessary to protect our rights, to enforce our Terms of Use, or to protect the rights, property or safety of our services, users or others; and to investigate fraud;
• Where all or substantially all of the business or assets of Many Rivers relating to our services are sold, assigned, or transferred to another entity; or
• Where, even if not described above, you have consented to such disclosure or Many Rivers has a legitimate interest in making the disclosure.

Many Rivers also may disclose navigational and transactional information in the form of anonymous, aggregate usage statistics and demographic information that does not reveal your identity or personal information.

SECURITY

We will use appropriate physical, technical and administrative safeguards to protect your data.  Access to your personal data will be restricted to only those who need to know that information and required to perform their job function.  In addition, we train our employees about the importance of maintaining the confidentiality and security of your information.

COOKIES

As is true of most web sites, we gather certain information automatically. This information may include IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

Many Rivers and its partners use cookies or similar technologies to analyze trends, administer the web site, track users’ movements around the web site, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our web site or services.

YOUR RIGHTS

You have the right to make a written request to be informed whether or not we hold or process any of your personal information (by emailing [email protected]). In your written request, you may:

• Request that we provide you with details of your personal information that we process, the purpose for which it is processed, the recipients of such information, the existence of any automated decision making involving your personal information, and what transfer safeguards we have in place;
• Request that we rectify any errors in your personal information;
• Request that we delete your personal information if our continued processing of such information is not justified;
• Request that we transfer your personal information to a third party;
• Object to automated decision-making and profiling based on legitimate interests or the performance of a task in the public interest (in which event the processing will cease except where there are compelling legitimate grounds, such as when the processing is necessary for the performance of a contract between us);
• Object to direct marketing from us; and
• Object to processing for purposes of scientific, historical research and statistics.

Where applicable under your local laws, we will not use your personal information for marketing purposes, nor disclose your information to any third parties, unless we have your prior consent, which we will seek before collecting your personal information. You can exercise your right to prevent such processing by checking certain boxes on the consent forms we use when collecting your personal information. If at any point you wish to review or change your preferences you can use the “opt-out” or unsubscribe mechanism or other means provided within the communications that you receive from us. Note that you may still receive transactional communications from Many Rivers. For queries, please contact [email protected]. 

YOUR CALIFORNIA DATA PRIVACY RIGHTS

Information About Data We Have Collected or Disclosed About You

The California Consumer Privacy Act (“CCPA”) provides additional data privacy rights to California residents. You have the right to request that we provide, not more than twice every 12 months, certain information about the data we have collected or disclosed about you over the past 12 months, including:

• the categories of personal information we have collected about you;
• the categories of sources from which we have collected your personal information;
• the business or commercial purpose for collecting your personal information;
• the categories of third parties with whom we share your personal information;
• the specific pieces of personal information we have collected about you; and
• the categories of personal information that we have disclosed about you for a business purpose.
• For the purposes of your rights as a California resident, “personal information” means any non-publicly available information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with you or your household, such as biometric information or information about your location.  

Disclosure of Personal Information

For certain of our business functions, we may disclose personal information for a business purpose. When we disclose personal information for a business purpose, the third party must agree to retain, use, or disclose the personal information solely for the business purpose. We prohibit the third party from selling the personal information that we provide [for a business purpose]. In the past 12 months, depending on how you interact with Many Rivers, we may have disclosed your information as set forth in the section above entitled “Disclosure and Sharing of Your information.”

Deletion of Data

California residents also have the right to request that we delete the personal information we have collected from you (and direct our service providers to do so), except where retaining your personal information is necessary for Many Rivers to:

• Complete your transaction, provide a good or service you requested, or perform a contract between you and us;
• Protect you or us from security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
• Fix errors in our systems;
• Protect your, our, or others’ right to free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (California Penal Code Section 1546 and following);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws;
• Use your personal information internally in a way that is reasonably aligned with your expectations based on your relationship with us or in another lawful manner that is compatible with the context in which you provided the information; or
• Comply with a legal obligation.

“Do Not Track” (for California and Delaware Residents)

Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers. For more information about “do not track”, go to https://allaboutdnt.com/.

How to Exercise Your Rights

To exercise your rights under CCPA, you may submit a verifiable consumer request to us by email at [email protected]. Only you, a person registered with the Secretary of State authorized to act on your behalf, or you on behalf of your minor child may submit a verifiable consumer request. The request must provide enough information for us to reasonably verify you are, or are the authorized representative of, the person about whom we collected personal information. We cannot reply if you do not comply with the foregoing.

LINKS TO THIRD-PARTY WEB SITES

Many Rivers web site or services may include links to third-party web sites. In using such links, please be aware that each third-party web site is subject to its own privacy and data protection policies and is not covered by our Privacy Policy.

RECOURSE

Any comments, complaints or questions concerning this policy or complaints or objections about our use of your personal information should be addressed by directing your comments to Many Rivers data protection email [email protected].

UPDATES TO THIS PRIVACY POLICY

Please note that Many Rivers Privacy Policy is reviewed periodically. Many Rivers reserves the right to update its Privacy Policy at any time without notice. Any changes to the Privacy Policy will be posted on this page and will become effective as of the Effective Date above. We encourage you to periodically review this page at https://davidwhyte.com/privacy-policy for any updates to this Privacy Policy.