PRIVACY POLICY
PRIVACY POLICY
Updated January 26th, 2023
At Riveter, (“Riveter”, “We”, “Us”) our mission is to use content, technology, and person to person interactions to help you explore your world, dream about, plan, and have the best trips possible. To do this, we ask You questions and learn about Your goals and priorities as they relate to travel, as well as details of trips You are taking or plan to take, and Your preferences related to our content. We may also use tracking technologies to detect information about you, and third parties may also do so in connection with our Services (see below).
We know You are putting your trust in us, and the privacy and security of your Personal Data, stands at the center of our commitment to you. Riveter’s policy is to respect Your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including via our app, Riveter, and its associated services.
For purposes of this privacy policy (the “Privacy Policy”), “Personal Data” means any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use an app or online service.
In the event our app contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our app.
LEGITIMATE REASONS FOR PROCESSING YOUR PERSONAL INFORMATION
We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.
INFORMATION WE COLLECT
Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.
“Voluntarily provided” information refers to any information you knowingly and actively provide us when using our app and its associated services.
“Automatically collected” information refers to any information automatically sent by your device in the course of accessing our app and its associated services.
Information includes:
Account information. We collect information that you provide, such as your name, email address, phone number, and physical address, when you use the Services to do things like create an account, purchase a subscription, subscribe to our newsletter, or contact us.
Payment Information. In the event we offer paid Services, either via subscription or via one-time payments, and You choose to purchase them, we may request payment information from you such as credit card type, certain digits of your card number, expiration date, and billing address, so that your payment can be processed. If Riveter uses a third party to process payments, those third parties for the processing of your payment and information will be done in accordance with their privacy policies.
Information you voluntarily provide. You may voluntarily provide certain information to us when you use the Services. For instance, when messaging with a Riveter Concierge, you may provide details related to your questions such as travel dates, budget, preferences, names of family or friends, location of accommodations, or activities already booked. You may also choose to enable certain settings or permissions on your device in order to use the Services, such as access to your camera or photo library. You may also provide information about yourself when contacting Us for support.
Interactions with the Riveter Host and Riveter Concierge. To better understand your needs and preferences, and help provide you with the best possible advice and recommendations, as well as to improve the Services overall, We collect and record your interactions with your Riveter Host and Riveter Concierge, including including in-app chats, as well as any photos, videos, or other media, if any, that you share with your Riveter Host and/or Riveter Concierge. Riveter uses this information to personalize our Services to your specific needs.
Product usage information. We collect information about the way you use our Services, such as actions you take in your account and the way you use Our website and the Riveter App. This information is used to identify ways to improve the Services as well as diagnose and troubleshoot issues.
Log Data. When you access our servers via our app, we may automatically log the standard data provided by your device. This may include your device's Internet Protocol (IP) address, your device type and version, your activity within the app, time and date, and other details about your usage.
Additionally, when you encounter certain errors while using the app, we automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
Device information. We may access and collect information from and about the devices you use to access our Services. This may include, IP addresses, operating system, the type of browser and device you use, language settings, and identifiers associated with your device. We may also access and collect data via your device’s built in tools such as location data, storage, photos and/or media, notifications, background data refresh, and mobile data.
When you install our App or use your device’s tools within the App, we request permission to access this information. The specific data we collect can depend on the individual settings of your device and the permissions you grant when you install and use the App.
Cookies and other tracking technologies. We may use tracking technologies like cookies, web beacons, and pixel tags (together, “Cookies”) to provide, improve, protect, and promote our Services. For example, we may use cookies to save your preferences across websites, understand how you use our Services and provide more personalized experiences. help us remember your preferences, understand how you interact with our Services, improve them based on that information, and improve them based on that information. We may also use third-party service providers - e.g. payment processors - who set cookies and similar technologies when you are on our Services or on other devices, apps, websites, or in the emails you may receive from them.
Location information. We may derive information about your location based on your IP address and use it to provide and protect our Services. For example, we may use your location information to determine whether our Services are available in your area or provided you with content relevant to your location.
Third Parties. We may also obtain information about you from third parties, including for instance: Corporate Affiliates (as defined below), joint marketing partners, lead providers, and fraud and risk mitigation vendors.
COLLECTION AND USE OF INFORMATION
Your Personal Information may be collected when do any of the following on our websites or in the Riveter App:
Register for an account
Sign up to receive updates from us via email or social media channels
Use a mobile device or web browser to access our content
Contact us via email, social media, or on any similar technologies
When you mention us on social media
We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
To provide you with our app and platform's core features and services
To enable you to customize or personalize your experience of our website
To contact and communicate with you
For analytics, market research, and business development, including to operate and improve our app, associated applications, and associated social media platforms
To enable you to access and use our app, associated platforms, and associated social media channels
For internal record keeping and administrative purposes
We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, If you consent to us accessing your social media profiles, we may combine information sourced from those profiles with information received from you directly to provide you with an enhanced experience of our app and services.
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
We may share your data with the following third parties to provide, protect, improve, and promote our Services:
A parent, subsidiary, or affiliate of our company.
Third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, and payment systems operators.
Our employees, contractors, and/or related entities. For example, the Riveter Concierges who are paired with you to answer your questions and provide you Services.
Our existing or potential agents or business partners.
Credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you.
Courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights.
Third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you.
Third parties we engage to collect and process data.
An entity that buys, or to which we transfer all or substantially all of our assets and business.
Third parties we currently use include:
Mixpanel
Apple
Pendo
RevenueCat
Twilio
The above list shall be updated if and when additional third parties are used.
In addition, there may be circumstances where we will share information about you with third parties at your request.
We may also use your Personal Data to generate de-identified and/or aggregated data, which we may use and share for any lawful purpose. For example, we may share your Personal Data on a de-identified or aggregated basis with Riveter Concierges, business partners, and academic researchers so they can understand general trends about our Services and its users.
SECURITY OF YOUR PERSONAL INFORMATION
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.
However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
CHILDREN’S PRIVACY
We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
The personal information we collect is stored and/or processed in the United States, or where we or our partners, affiliates, and third-party providers maintain facilities.
The countries to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.
YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION
Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our app or the products and/or services offered on or through it.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Access: You may request details of the personal information that we hold about you.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example serving particular content to your device), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.
BUSINESS TRANSFERS
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
LIMITS OF OUR POLICY
Our app may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
CHANGES TO THIS POLICY
At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here and on our website.
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.
If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.
ADDITIONAL DISCLOSURES FOR AUSTRALIAN PRIVACY ACT COMPLIANCE (AU)
International Transfers of Personal Information
Where the disclosure of your personal information is solely subject to Australian privacy laws, you acknowledge that some third parties may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act. You acknowledge that if any such third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act, and you will not be able to seek redress under the Privacy Act.
ADDITIONAL DISCLOSURES FOR GENERAL DATA PROTECTION REGULATION (GDPR) COMPLIANCE (EU)
Data Controller / Data Processor
The GDPR distinguishes between organizations that process personal information for their own purposes (known as “data controllers”) and organizations that process personal information on behalf of other organizations (known as “data processors”). We, Riveter, located at the address provided in our Contact Us section, are a Data Controller with respect to the personal information you provide to us.
Legal Bases for Processing Your Personal Information
We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose.
Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:
Consent From You: Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however this will not affect any use of your information that has already taken place. You may consent to providing your email address for the purpose of receiving marketing emails from us. While you may unsubscribe at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.
Performance of a Contract or Transaction: Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, we need technical information about your device in order to provide the essential features of our app.
Our Legitimate Interests: Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. For example, we collect technical information about your device in order to improve and personalize your experience of our app. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.
Compliance with Law: In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further enquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.
INTERNATIONAL TRANSFERS OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)
We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION
Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.
Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may also have the right to request that we transfer this personal information to a third party.
Deletion: You may have a right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of our app, website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you terminate or delete your account, we will delete your personal information within 5 days of the deletion of your account. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.
CONTACT US
For any questions or concerns regarding your privacy, you may contact us using the following email:
Please use the subject line: Privacy Concerns