Privacy Policy
Last Updated: January 23, 2020
RIWI Corp. (“RIWI”, “we,” or the “Company”) takes the anonymity of personal information, and the ethical collection and storage of all personal information, very seriously. We encourage you to read this Privacy Policy (the “Policy”) before using this site. If you have questions regarding this Policy, please contact us via email at: privacy@riwi.com
Personally Identifiable Information
“Personally identifiable information” is any information relating to an individual, whether it relates to his or her private, professional or public life. It can be anything from a name, a home address, a photo, an email address, bank details, posts on social networking websites or medical information. More details on personally identifiable information and the definition of “personal data” are described below, with specific examples relevant to the usage of this website and to RIWI services.
Further definitions mentioned herein are described further down in this Policy.
Summary of RIWI Privacy Policy
RIWI is committed to the pursuit of best practices in data anonymity and data privacy and digital rights. No personally identifiable information is collected, stored or transferred using RIWI surveys or ad tests. From European Union (“EU”) countries, no “personal data” are collected by RIWI. “Personal data” include Internet Protocol (IP) addresses. No personal data are collected from users of the riwi.com website except in one case only: specifically, information collected from the Contact Form (the “Contact Form”; See: https://riwi.com/contact/). Explicit consent of users of the Contact Form is required before RIWI personnel may contact anyone who has filled out and submitted their contact information electronically via the Contact Form. By “explicit consent,” we mean that RIWI personnel may only contact someone who has completed the Contact Form and who expresses demonstrable written interest through the Contact Form in learning about RIWI services. The sole purpose of the Contact Form is to respond to expressions of interest from people interested in potentially buying or learning more about RIWI services, or, in the case of media or job or investor inquiries, from reporters or job candidates or investors wishing to learn more about the Company (collectively, “Persons”).
The personal information collected through the Contact Form allows RIWI to:
- Establish the accuracy of a Person’s identity; and
- Determine a Person’s suitability for a RIWI product or service
(collectively, “Contact Purposes”)
The aforementioned personal information will only be used for the Contact Purposes for which it was collected as described above. Said information will not be shared with any third parties except with Akismet™ to reduce spam. RIWI does not distribute electronic newsletters or promotional content to Persons completing the Contact Form. Once Persons’ contact information is entered and submitted to the Company via the Contact Form, Persons may request RIWI’s destruction of all records of their aforementioned personal identifiable information entered into the Contact Form, including their name, email address and phone number, by sending an email to privacy@riwi.com. Persons are therefore able at any time to withdraw consent for RIWI to use their personal information for Contact Purposes by contacting RIWI at the email address noted above. Persons have the right to verify the accuracy and completeness of their personal information submitted via the Contact Form, and may request that it be amended. Please note that RIWI may not make the change if the changed information is no longer needed to fulfill Contact Purposes.
The contact form uses Akismet to reduce spam. Only the personal data needed to carry out Akismet’s core function of protecting against spam are collected from the contact form. Akismet does not sell the data you send, and they do not keep the data for long periods. Akismet has short retention periods of between two weeks and ninety days for the vast majority of spam-related data, at which point the data are automatically deleted from Akismet databases. See https://akismet.com/privacy/
Google Analytics™ outside the European Union
Outside the European Union (“EU”), our website uses Google Analytics™, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.
European Union Data Collection from Survey Sites
Information Collection through Surveys or Ad Tests: No Personally Identifiable Data, No Personal Data and No Cookies
From any persons located in the European Union (“EU”) who encounter the Company’s survey sites (the “Survey Sites”), the Company does not collect, process, store or transfer personal information such as anyone’s name, mailing address, e-mail address and phone number. The Company may collect and store anonymous information from a Survey Site that is untraceable to any person, specifically, what someone may think about a certain topic or issue. The Company does not collect personal data in EU countries, such as an IP address. The voting pages on Survey Sites in the EU are ‘cookie-less’ so that no cookies remain. See below for more information on cookies.
The Company does not use a “cookie” or pixel of any kind on any Survey Site in EU countries.
On its Survey Sites, the Company does not collect, process, store or transfer personally identifiable information through technologies such as cookies, log files, clear gifs (also known as Web beacons), and other technologies to help determine user viewing preferences for advertising and/or other purposes.
On its Survey Sites, the Company does not collect, process, store or transfer “personal data”, including any IP address, as understood by the terms of the General Data Protection Regulation (“GDPR”) in EU law on data protection and privacy for all individuals within the European Union. All data collected from any Survey Site are anonymous and are untraceable to any personal data or to any personally identifiable data. According to the GDPR, “personal data is any information relating to an individual, whether it relates to his or her private, professional or public life. It can be anything from a name, a home address, a photo, an email address, bank details, posts on social networking websites, medical information, or a computer’s IP address.” From the EU, the Company does not collect, process, store or transfer any personal data as understood by the GDPR.
Data Collection from Survey Sites outside of EU Countries
Information Collection: No Personally Identifiable Information
From any persons located outside of the EU who encounter the Company’s Survey Sites, the Company does not collect, process, store or transfer personal information such as someone’s name, mailing address, e-mail address and phone number. The Company may collect and store anonymous information from a Survey Site that is untraceable to any person, specifically, what someone may think about a certain topic or issue.
On its Survey Sites outside of the EU, the Company does not collect, process, store or transfer “personally identifiable information”. All data collected on Survey Sites are anonymous. “Personally identifiable information” is any information relating to an individual, whether it relates to his or her private, professional or public life. It can be anything from a name, a home address, a photo, an email address, bank details, posts on social networking websites or medical information.
CCPA OVERVIEW and RIWI
A new privacy law, the California Consumer Privacy Act (“CCPA”), which provides California consumers certain rights regarding their personal information, became effective on January 1, 2020. However, as of that date the California Attorney General had not completed the rule-making process to establish the regulations for businesses to implement the law.
As such:
We do not collect or store personal information (PI) from California-based consumers on our survey and data platform.
We do not use third-party cookies.
Cookie sessions are limited to 4 hours, and then dropped afterwards.
Cookies do not contain PI and are only used for proper website functioning.
IP addresses and user agent data are anonymized.
Latitude/longitude coordinates are dropped.
More broadly:
No personal identifiers nor PI are retained by RIWI.
No personal records are collected or retained by RIWI. Such records would include name, postal address and telephone number.
No personal characteristics and traits that can be linked to an individual are collected or retained by RIWI.
No commercial information that can be linked to an individual is collected or retained by RIWI. This information would include products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
No Internet usage information is collected or retained by RIWI. This information would include browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
No inferences from PI can be made since PI is not collected or retained by RIWI. Such inferences would include consumer preferences, characteristics, psychological trends, predispositions, behavior, and attitudes.
Additional Definitions
Cookies. A cookie is a piece of data stored on a user’s browser that can track non-personal information or personal data about the user. The Company does not use cookies as understood by this definition.
An (Internet Protocol) IP address is a number that’s automatically assigned to your computer whenever you’re surfing the Web. Web servers (the big computers that send (serve up) Web pages) can identify your computer by its IP address. The Company does not collect, process, store or transfer any IP address data as understood by the GDPR.
Where is Personal Information from the RIWI Contact Form kept?
Personal information in our possession from the Contact Form, for the limited purposes described above, may be kept in electronic format in the offices of RIWI.
Protecting Personal Information Collected from the RIWI Contact Form
Policies, procedures, guidelines, and safeguards have been put in place at RIWI to ensure personal information sent to RIWI is protected in accordance with Canadian privacy legislation. Security measures including passwords, restricted access to our offices and records, physical access security have been put in place to protect personal information against unauthorized access, theft or misuse.
Our employees and service providers have access to the limited above-noted personal information to enable them to perform their duties. Each RIWI employee is responsible for ensuring the confidentiality of all personal information accessed from the Contact Form. As a condition of employment, every employee must sign a code of conduct, which includes comprehensive provisions ensuring the protection of personal information.
As noted, RIWI does not collect any personal information from visitors browsing our website although personally identifiable information may be requested if a visitor chooses to send RIWI an email message.
Questions and Concerns
Inquires received will be reviewed by RIWI’s Chief Privacy Officer. Contact information for RIWI’s Chief Privacy Officer is provided below:
RIWI Chief Privacy Officer Neil Seeman, Chief Executive Officer Tel: 416.205.9984 E-Mail: privacy@riwi.com Mailing Address: RIWI Corp. 180 Bloor Street West Suite 1000 Toronto, ON, M5S 2V6. We will respond to all questions and concerns in a timely fashion.
Data Privacy Policy Changes
This Policy may be updated from time to time. If you have questions regarding this Policy, please contact us via email at: privacy@riwi.com
