Effective as of January 1, 2020
Last updated April 21, 2023
- Information We Collect Online
- How We Use Your Information
- How We Share Your Information
- Cookies and Other Tracking Technologies
- “Do Not Track” Signals
- Choices About Your Personally Identifiable Information
- Third Party Links
- Children’s Privacy
- Notice to Nevada Residents
- Notice to California Residents
- Notice to Residents of Europe Economic Area and the U.K.
- How to Contact Us
1. INFORMATION WE COLLECT ONLINE
We collect Personally Identifiable Information from you through your use of the Site and Services. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:
Information You Provide
We may collect the following Personally Identifiable Information that you voluntarily provide to us in using our Site and Services:
- Account. If you create an account, you will provide us with your first and last name, email address, phone number, institution/organization, physical address, and password. When you log-in to your account, you will provide us with your email address and password.
- If you subscribe to our blog, we will require you to provide your first and last name and email address. If you share a blog post on a social media platform, we may collect the information that you post.
- Webinar & Event Registration. If you register for a conference or webinar, you will provide us with your first and last name, email address, phone number, and state.
- RNL Marketplace. If you are interested in joining or learning more about the RNL Marketplace, you will provide us with your first and last name, email address, and phone number.
- Learn More from RNL Partners. To learn more about specific RNL partners on the RNL Marketplace, you will provide us with your first and last name, email address, job title, institution/organization, and phone number.
- Request a Consultation or Walkthrough. If you “Request a Consultation” or “Walkthrough” for Fundraising, a Campus Visit, Graduate and Online Enrollment Management, the RNL Digital Engagement Center, RNL QuadWrangle, RNL Career Services, or the RNL OPM Alternative, you will provide us with your first and last name, email address, state, and phone number.
- Request for Proposal. If you contact the RNL proposal team on behalf of your college/university, you may provide us with your first and last name, email address, phone number, and state.
- Contact Us. When you send us any feedback, questions, comments, suggestions, ideas, or interact with us in any way, we will receive your first and last name, email address, phone number, institution/organization, and interest area.
Information as You Navigate Our Site
We automatically collect certain Personally Identifiable Information through your use of the Site and Services, such as the following:
- Usage Information. For example, the pages on the Site you access, the frequency of access, and what you click on while on the Site.
- Device Information. For example, hardware model, operating system, application version number, and browser.
- Mobile Device Information. Aggregated information about whether the Site is accessed via a mobile device or tablet, the device type, and the carrier.
- Location Information. Location information from Site visitors on a city-regional basis.
Third Party Information
2. HOW WE USE YOUR INFORMATION
We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and Site, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:
- Process your account registration;
- Email you our blog posts;
- Contact you regarding our products and services that we feel may be of interest to you;
- Communicate with you about our Site or Services or to inform you of any changes to our Site or Services;
- Provide support;
- Maintain and improve our Site and Services;
- Protect the security and integrity of our Site and Services;
- Defend our legal rights and the rights of others;
- Fulfill any other purposes for which you provide it, or any other purpose we deem necessary or appropriate;
- Efficiently maintain our business; and
- Comply with applicable law.
3. HOW WE SHARE YOUR INFORMATION
We may share the information that we collect about you in the following ways:
- With vendors who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
- With vendors to prepare, deploy and analyze advertising content;
- To the extent that we are required to do so by law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise, or defend our or a third party’s legal rights, including providing information to others for the purposes of fraud prevention;
- With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personally Identifiable Information;
- With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events;
- With any other person or entity where you consent to the disclosure; And
- For any other purpose disclosed by us when you provide the Personally Identifiable Information or for any other purpose we deem necessary, including to protect the health or safety of others.
4. COOKIES AND OTHER TRACKING TECHNOLOGIES
5. “DO NOT TRACK” SIGNALS
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
6. CHOICES ABOUT YOUR PERSONALLY IDENTIFIABLE INFORMATION
Review and Request Changes to Your Personally Identifiable Information
You may use your account to access, correct, or view certain Personally Identifiable Information we have collected and which is associated with your account. To review or request changes to any of your Personally Identifiable Information, please contact us at ContactUs@RuffaloNL.com.
To unsubscribe from our marketing emails or mailings, please follow the “unsubscribe” or “opt-out” instructions/link provided in such emails and mailings. You also may submit a request to us at ContactUs@RuffaloNL.com.
Please note that, despite any indicated email marketing preferences, we may send you administrative emails regarding RNL, including, for example, notices concerning conferences that you have registered for or services you have purchased.
We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.
8. THIRD-PARTY LINKS
9. CHILDREN’S PRIVACY
The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.
10. NOTICE TO NEVADA RESIDENTS
Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to ContactUs@RuffaloNL.com.
11. NOTICE TO CALIFORNIA RESIDENTS
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
Right to Know About Personal Information Collected, Disclosed, or Sold
If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:
- Specific pieces of Personal Information that we have collected about you;
- Categories of Personal Information that we have collected about you;
- Categories of sources from which the Personal Information was collected;
- Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
- Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
- The business or commercial purpose for collecting or, if applicable, selling Personal Information.
Collection of Personal Information
- Identifiers (name, postal address, online identifier, internet protocol address, email address, account name)
- Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
- Telephone number
- Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
- Commercial information (areas of interest (e.g., medicine, English, etc.) and higher education institutions of interest)
- Geolocation data
- Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
The Personal Information is collected from California residents directly and from advertising networks, internet service providers, data analytics providers, and data brokers. Not all categories of Personal Information are collected from each source.
In addition to the purposes stated above in the section “Collecting and Using Information,” we currently collect and have collected and sold the above categories of Personal Information for the following business or commercial purposes:
- Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Performing services on behalf of RNL or another business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing advertising or marketing services, providing analytic services, or providing similar services
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of our services and to improve, upgrade, or enhance same
- Commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
Disclosure or Sale of Personal Information
|Category of Personal Information||Category of Service Providers||Category of Third Parties|
|Name, email address; employment information (institution name; job title; department, state)||Research sponsors|
|Online identifier; IP address; device identifier; geolocation data||Data analytics provider|
|Email address||Email service provider|
|Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement||Data analytics provider; marketing services provider||Advertising networks|
|Inferences drawn from personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||Advertising platforms|
We do not knowingly sell the Personal Information of minors under 16 years of age.
Right to Request Deletion of Personal Information
If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
How to Submit a Request to Know or Delete
You may submit a request to know or delete by emailing us at ContactUs@RuffaloNL.com or calling us at 1-800-707-4871.
Our Process for Verifying a Request to Know or Delete
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.
We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.
For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
Right to Opt-Out of Sale of Personal Information
If you are a California resident, you have the right to direct us to stop selling your Personal Information.
The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.
You may submit a request to opt-out of sales clicking this button:
Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights
We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.”
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.
Shine the Light Law
We do not disclose personal information obtained through our Site or Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.
13. NOTICE TO RESIDENTS OF EUROPE ECONOMIC AREA AND THE U.K.
The Site and Services are operated by RNL, a company located in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (GDPR) or Article 74 of the United Kingdom’s Data Protection Act (UK GDPR). To the extent required, we rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we collect and transfer to the United States personal data only: with your consent, to perform a contract with you, or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. Where our processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before your withdrawal. If you are located outside of the United States, please be aware that information we collect will be processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. We retain data for the duration of your business relationship with us and for a period of time thereafter to analyze our own operations, and for historical and archiving purposes associated with ongoing activities. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at ContactUs@RuffaloNL.com.
Reasonable access to your personal data will be provided at no cost to you upon request made to us at ContactUs@RuffaloNL.com. If access cannot be provided within a reasonable timeframe, we will provide you with a date when the information will be provided. If for some reason access is denied, we will provide an explanation as to why access has been denied.
14. HOW TO CONTACT US
Ruffalo Noel Levitz, LLC
Attn: Chief Information Security Officer
5249 North Park Place NE, #1061
Cedar Rapids, IA 52402