PRIVACY POLICY

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Privacy Notice

Effective Date: October 9, 2018

Notice Version: 1.0

Data Controller / Contact Information

RCP Institute, LLC
418 Fairoaks Circle
Chapel Hill, NC. 27516

This document governs the privacy notice of our website https://therootcauseprotocol.com

Our privacy notice tells you what personal data (PD) and non-personal data (NPD) we may collect from you, how we collect it, how we protect it, how we may share it, how you can access and change it, and how you can limit our sharing of it. Our privacy notice also explains certain legal rights that you have with respect to your personal data. Any capitalized terms not defined herein will have the same meaning as where they are defined elsewhere on our website.

Definitions

‘Non-personal data’ (NPD) is information that is in no way personally identifiable.
‘Personal data’ (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data.

A “visitor” is someone who merely browses our website. A “member” is someone who has registered with us to use or buy our services and products. The term “user” is a collective identifier that refers to either a visitor or a member.

Topics Covered in Our Privacy notice

YOUR RIGHTS

INFORMATION WE COLLECT AND HOW WE COLLECT IT

OUR USE OF COOKIES
HOW YOUR INFORMATION IS USED
RETAINING AND DESTROYING YOUR PD
UPDATING YOUR PD

REVOKING YOUR CONSENT FOR USING YOUR PD

PROTECTING THE PRIVACY RIGHTS OF THIRD PARTIES

DO NOT TRACK SETTINGS

LINKS TO OTHER WEBSITES

PROTECTING CHILDREN’S PRIVACY

OUR EMAIL POLICY
OUR SECURITY POLICY

USE OF YOUR CREDIT CARD

TRANSFERRING PD FROM THE EUROPEAN UNION

CHANGES TO OUR PRIVACY NOTICE

YOUR RIGHTS
When using our website, services, and submitting PD to us, you may have certain rights under the General Data Protection Regulation (GDPR) if you reside or are in any of the countries of the European Union. Depending on the legal basis for processing your PD, you may have some or all of the following rights:

The right to be informed

You have the right to be informed about the PD we collect from you, and how we process it.

The right of access

You have the right to get confirmation that your PD is being processed and have the ability to access it.

The right to rectification
You have the right to have your PD corrected if it is inaccurate or incomplete.

The right to erasure (right to be forgotten)
You have the right to request the removal or deletion of your PD if there is no compelling reason for us to continue processing it.

The right to restrict processing
You have a right to ‘block’ or restrict the processing of your PD. When your PD is restricted, we are permitted to store your data, but not to process it further.

The right to data portability

You have the right to request and get your PD that you provided to us and use it for your own purposes. We will provide your data to you within 30 days of your request. To request your PD, please contact us using the information at the top of this privacy notice.

The right to object
You have the right to object to us processing your PD for the following reasons:

• Processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
• Direct marketing (including profiling); and
• Processing for purposes of scientific/historical research and statistics.
• Rights in relation to automated decision-making and profiling.

Automated individual decision-making and profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects regarding you or similarly significantly affects you.

Filing a complaint with authorities

You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the General Data Protection Regulation. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.

For details about your rights under the law, visit https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/

INFORMATION WE COLLECT AND HOW WE COLLECT IT

Generally, you control the amount and type of information that you provide to us when using our website.

Our Legal Basis for Collecting and Processing PD

Our legal basis for collecting and processing your PD when you buy our products or services is based on and the necessity for the performance of a contract or to take steps to enter into a contract. Our legal basis for collecting and processing your PD when you sign up for our newsletter and information about our products and services through our website opt-in forms is based on consent.

Automatic Information

We automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered our website, if any, as well as the name of the website you’ll visit when you leave our website. This information may also include the IP address of your computer/the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, your computer operating system, and data about your browsing activity when using our website. We use all this information to analyze trends among our users to help improve our website.

When Entering and Using Our Website

When you enter and use our website and agree to accept cookies, some of these cookies may contain your PD.

At User and Member Registration or When Buying Products or Services

When you register as a user, member, or when buying our products or services, we may collect some or all of the following information: your first and last name, email address, physical address, credit card or other payment information, phone number, user name, password, and other information listed.

OUR USE OF COOKIES

Our website uses cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well.

By agreeing to accept our use of cookies, you are giving us, and third parties we partner with, permission to place, store, and access some or all the cookies described below on your computer.

Strictly Necessary Cookies

These cookies are necessary for proper functioning of the website, such as displaying content, logging in, validating your session, responding to your request for services, and other functions. Most web browsers can be set to disable the use of cookies. However, if you disable these cookies, you may not be able to access features on our website correctly or at all.

Performance Cookies

These cookies collect information about the use of the website, such as pages visited, traffic sources, users’ interests, content management, and other website measurements.

Functional Cookies

These cookies enable the website to remember a user’s choices – such as their language, user name, and other personal choices – while using the website. They can also be used to deliver services, such as letting a user make a blog post, listen to audio, or watch videos on the website.

Media Cookies

These cookies can be used to improve a website’s performance and provide special features and content. They can be placed by third parties who provide services to us or by our company.

Advertising or Targeting Cookies

These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests. You will see less advertising if you disable these cookies.

Session Cookies

These cookies allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they browse a website. Session cookies also permit users to be recognized as they navigate a website so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; thus, they are not stored long term.

Persistent Cookies
These cookies are stored on a user’s device in between browser sessions, which allows the user’s preferences or actions across a site (or, in some cases, across different sites) to be remembered. Persistent cookies may be used for a variety of purposes, including remembering users’ choices and preferences when using a website or to target advertising to them.

We may also use cookies for:

• Identifying the areas of our website that you have visited
• Personalizing content that you see on our website
• Our website analytics
• Remarketing our products or services to you
• Remembering your preferences, settings, and login details
• Targeted advertising and serving ads relevant to your interests
• Affiliate marketing
• Allowing you to post comments
• Allowing you to share content with social networks

Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access features on our website correctly or at all.

Web Beacons

We may also use a technology called web beacons to collect general information about your use of our website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers, members, and visitors.

Google Analytics Privacy Notice

Our website uses Google Analytics to collect information about the use of our website. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our website, what pages they visit, and what other websites they have used before coming to our website. We use the information we get from Google Analytics to analyze traffic, remarket our products and services to users, improve our marketing, advertising, and to improve our website. We have enabled Google Analytics advertising features such as remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. Google Analytics collects only the IP address assigned to you on the date you visit our website, not your name or other identifying information. We do not combine the information collected using Google Analytics with PD. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our website, the cookie cannot be used by anyone but Google. Google also uses specific identifiers to help collect information about the use of our website. For more information on how Google collects and processes your data, visit https://www.google.com/policies/privacy/partners/

You can prevent Google Analytics from using your information by opting out at this link:https://tools.google.com/dlpage/gaoptout

Other Analytics Services

Our website uses analytics services from several other companies other than Google to collect information about the use of our website. Analytics collects information such as how often users visit our website, what pages they visit, when they do so, what other websites they used before coming to our website, and their IP address. We use the information we get from analytics to improve our services.

Gravatar Disclosure

We use a service from www.en.gravatar.com that allows you to have an image that represents you when you are online. It is a picture that appears next to your name when you Interact with different websites that are Gravatar enabled. To make this happen, a tracking mechanism is used that follows you from website to website.

What Happens If You Don’t Give Us Your PD
If you do not provide us with enough PD, we may not be able to provide you with all our products and services. However, you can access and use some parts of our website without giving us your PD.

HOW YOUR INFORMATION IS USED
We use the information we receive from you to:

• Provide our products and services you have requested or purchased from us
• Personalize and customize our content
• Make improvements to our website
• Contact you with updates to our website, products, and services
• Resolve problems and disputes
• Contact you with marketing and advertising
  that we believe may be of interest to you

Communications and Emails

When we communicate with you about our website, we will use the email address you provided when you registered as a member or user. We may also send you emails with promotional information about our website or offers from us or our affiliates unless you have opted out of receiving such information. You can change your contact preferences at any time through your account or by contacting us using the contact information at the top of this privacy notice.

Sharing Information With Affiliates and Other Third Parties

We do not sell or rent your PD to third parties for marketing purposes. We may provide your PD to third-party service providers we hire to provide services to us. These third-party service providers may include but are not limited to: payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies.

Sharing Information with Other Third Parties and Social Media Websites

We may share your information with third parties by using an Application Program Interface “API.” Such third parties may include Facebook.com, Twitter.com, YouTube.com, Instagram.com, and Google.com. If you decide to login using these third parties or other social media websites, you are agreeing to let us use and store your profile information from those websites to make better use of any social media features in our website. This sharing of information helps us provide you with a better experience when using our website and services. It also provides us with useful information such as visitor traffic. If you use any of the social sharing icons on our website to share our information, you may also be sharing your own personal information through social media websites.

Legally Required Releases of Information

We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our terms and conditions; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users or members; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.

Disclosures to Successors

If our business is sold or merges in whole or in part with another business that would become responsible for providing the website to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy notice as well as to any changes to this privacy notice as instituted by the new business. We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or business.

Community Discussion Boards

Our website may offer the ability for users to communicate with each other through online community discussion boards or other mechanisms. We donot filter or monitor what is posted on such discussion boards. If you choose to post on these discussion boards, you should use care when exposing any PD, as such information is not protected by our privacy notice nor are we liable if you choose to disclose your PD through such postings. Also, PD you post on our website for publication may be available worldwide by means of the Internet. We cannot prevent the use or misuse of such information by others.

RETAINING AND DESTROYING YOUR PD
We retain information that we collect from you (including your PD) only for as long as we need it for legal, business, or tax purposes. Your information may be retained in electronic form, paper form, or a combination of both. When your information is no longer needed, we will destroy, delete, or erase it.

UPDATING YOUR PD
You can update your PD using services found on our website. If no such services exist, you can contact us using the contact information found at the top of this privacy notice and we will help you. However, we may keep your PD as needed to enforce our agreements and to comply with any legal obligations.

REVOKING YOUR CONSENT FOR USING YOUR PD

You have the right to revoke your consent for us to use your PD at any time. Such an optout will not affect disclosures otherwise permitted by law including but not limited to: (i) disclosures to affiliates and business partners, (ii) disclosures to third-party service providers that provide certain services for our business, such as credit card processing, computer system services, shipping, data management services, (iii) disclosures to third parties as necessary to fulfill your requests, (iv) disclosures to governmental agencies or law enforcement departments, or as otherwise required to be made under applicable law, (v) previously completed disclosures to third parties, or (vi) disclosures to third parties in connection with subsequent contests or promotions you may choose to enter, or third-party offers you may choose to accept. If you want to revoke your consent for us to use your PD, please contact us using the contact information at the top of this privacy notice.

PROTECTING THE PRIVACY RIGHTS OF THIRD PARTIES

If any postings you make on our website contain information about third parties, you must make sure you have permission to include that information in your posting. While we are not legally liable for the actions of our users, we will remove any postings about which we are notified, if such postings violate the privacy rights of others.

DO NOT TRACK SETTINGS

Some web browsers have settings that enable you to request that our website not track your movement within our website. Our website does notobey such settings when transmitted to and detected by our website. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.

LINKS TO OTHER WEBSITES

Our website may contain links to other websites. These websites are not under our control and are not subject to our privacy notice. These websites will likely have their own privacy notices. We have no responsibility for these websites and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the privacy notices of these websites to see how they treat your PD.

PROTECTING CHILDREN’S PRIVACY

Even though our website is not designed for use by anyone under the age of 16, we realize that a child under the age of 16 may attempt to access our website. We do not knowingly collect PD from children under the age of 16. If you are a parent or guardian and believe that your child is using our website, please contact us. Before we remove any information, we may ask for proof of identification to prevent malicious removal of account information. If we discover that a child is accessing our website, we will delete his/her information within a reasonable period of time. You acknowledge that we do not verify the age of our users nor do we have any liability to do so.

OUR EMAIL POLICY
You can always opt out of receiving further email correspondence from us or our affiliates. We will not sell, rent, or trade your email address to any unaffiliated third party without your permission except in the sale or transfer of our business, or if our company files for bankruptcy.

OUR SECURITY POLICY

We have built our website using industry-standard security measures and authentication tools to protect the security of your PD. We and the third parties who provide services for us, also maintain technical and physical safeguards to protect your PD. When we collect your credit card information through our website, we will encrypt it before it travels over the Internet using industry-standard technology for conducting secure online transactions. Unfortunately, we cannot guarantee against the loss or misuse of your PD or secure data transmission over the Internet because of its nature.

We strongly urge you to protect any password you may have for our website and to not share it with anyone. You should always log out of our website when you finish using it, especially if you are sharing or using a computer in a public place.

USE OF YOUR CREDIT CARD
You may have to provide a credit card to buy products and services from our website. We use third-party billing services and have no control over these services. We use our commercially reasonable efforts to make sure your credit card number is kept strictly confidential by using only third-party billing services that use industry-standard encryption technology to protect your credit card number from unauthorized use. However, you understand and agree that we are in no way responsible for any misuse of your credit card number.

TRANSFERRING PD FROM THE EUROPEAN UNION

(PD) that we collect from you may be stored, processed, and transferred between any of the countries in which we operate, specifically the United States.The European Union has not found the United States and some other countries to have an adequate level of protection of PD under Article 45 of the GDPR. Our company relies on derogations for specific situations as defined in Article 49 of the GDPR. For European Union customers and users, with your consent, your PD may be transferred outside the European Union to the United States when you request information from us. We will use your PD to provide the goods and services you buy from us for the performance of a contract or to take steps to enter into a contract. Wherever we transfer, process or store your PD, we will take reasonable steps to protect it. We will use the information we collect from you in accordance with our privacy notice. By using our website, services, or products, you agree to the transfers of your PD described within this section.

CHANGES TO OUR PRIVACY NOTICE

We reserve the right to change this privacy notice at any time. If our company decides to change this privacy notice, we will post those changes on our website so that our users and customers are always aware of what information we collect, use, and disclose. If at any time we decide to disclose or use your PD in a method different from that specified at the time it was collected, we will provide advance notice by email (sent to the email address on file in your account). Otherwise we will use and disclose our users’ and customers’ PD in agreement with the privacy notice in effect when the information was collected. In all cases, your continued use of our website, services, and products after any change to this privacy notice will constitute your acceptance of such change. If you have any questions about our privacy notice, please contact us using the information at the top of this privacy notice.

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