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1. PRIVACY STATEMENT
RAPP recognizes
that privacy of information is important. Particularly,
protecting the privacy of those whose personal data we store and
process is an important concern to which the Company pays special
attention. Therefore, this privacy statement provides an overview
about the information the Company collects and stores, how the
Company uses that information, and how individuals may opt out of
certain uses of information we may collect and store.
By visiting our site, a party consents to the information
collection and use practices described in this privacy statement.
This privacy statement may be modified from time to time. If we
decide to change this privacy statement, we will post a new privacy
statement in-house and on our Web site and change the date at the
top of the privacy statement. Therefore, we encourage our staff,
our clients and the public in general to check the date of our
privacy statement whenever they visit the Web site for any updates
or changes.
Personal information collected during visits to our Web site or
stored by us is processed by us according to the legal provisions
valid for the countries in which our Web site is maintained.
Our Web site may include, however, links to other Web sites which
are not covered by this online privacy statement. These sites have
their own privacy and information security policies and terms and
conditions. The public is encouraged to review the privacy policy
and terms and conditions sections of such Web sites for additional
details.
1.1. Information RAPP Collects and Stores
RAPP may, at various times, collect and store several types of
information. Personal Information is information that identifies
an individual or is directly associated with a specific person,
such as an individual's name, mailing address, telephone number,
e-mail address, credit card number or information about activities
which can be directly linked to that person, such as his or her
purchases ("Personal Information"). Our definition of Personal
Information does not include "aggregate" information. Aggregate
information is data about use of our services. Aggregate information
helps us understand trends and clients' needs so that we can
better consider new services, and tailor existing services to
client desires.
We may also collect and store "Non-Personal Information", which is
information about a person who cannot be readily identified on an
individual basis. Examples of Non- Personal Information include
age range and gender.
1.1.1. Collection of Personal Information
We may collect and store certain kinds of Personal Information,
including Personal Information of third parties:
Client Service Correspondence: We may collect and store information
that identifies an individual personally when that individual
submits comments, questions resumes, etc.
Transactions: We may collect and store Personal Information to
fulfill an order for RAPP's clients' services. Such information
could include name and address, credit card number and expiration date,
and billing address.
Services: In providing services and manipulating data provided by
our clients' customers, we may collect and store Personal Information,
including personal information related to Third Parties.
1.1.2. Use of Personal Information
Except for marketing purposes or as otherwise disclosed in this
statement, we do not sell or disclose information that identifies
our clients or their customers, or makes it possible for other
parties to contact them directly without their consent. We may use,
sell, disclose or otherwise dispose of Personal Information we
collect in the following circumstances:
Inquiry. We use Personal Information provided to us by our
clients and/or their customers for services rendered. We do not
share this information with other parties unless such a request
was specified during the inquiry by our client and/or their customers.
Transaction Processing. We may use Personal Information provided
by a client and/or their customers when completing a transaction.
Also, we may share transactional information with entities as is
necessary to process credit card payments or other purchasing or
delivery systems. We may use an individual's e- mail address to
communicate with the individual or notify the individual of our
clients' special offers or programs.
Marketing research. We may store Personal Information and use it for
marketing research and marketing purposes, which may include
sharing it with various suppliers that provide marketing, research
or other services for us. We enter into contractual agreements with
these companies prohibiting them from disclosing or using our client
information other than to carry out the purposes for which the
information was disclosed.
Legal Requirements. We may disclose Personal Information: (a) to
conform with the law, respond to claims or comply with legal
process served on RAPP (e.g., a lawful subpoena, warrant or court
order); (b) to enforce or apply our policies or agreements
(including to initiate, render, bill, and collect for amounts
owed to us); (c) to protect and defend our or our clients' rights
or property, our employees, visitors or the public; or (d) if we
reasonably believe that an emergency involving immediate danger of
death or serious physical injury to any person requires disclosure
of communications or justifies disclosure of records without delay.
1.1.3. Use of Non-Personal and Aggregate Information
We may use Non-Personal and Aggregate information to better
design our services and share with our marketing and advertising
agencies.
1.2. Freedom of Choice
If an individual would like his Personal Information to not
be available to any third party, that party may contact us by
sending an e-mail to privacy@rappcollins.com so we can block the
applicable data accordingly.
1.3. California Privacy Rights
Under California's "Shine the Light" law, California residents
who provide Personal Information in obtaining services for personal,
family or household use are entitled to request and obtain from us
once a calendar year information about the information we shared,
if any, with other businesses for their own direct marketing uses.
If applicable, this information would include the categories of
personal information and the names and addresses of those businesses
with which we shared personal information for the immediately prior
calendar year (e.g. requests made in 2005 will receive information
regarding 2004 sharing activities).
To obtain this information, a California resident may e-mail us at
privacy@rappcollins.com with "Request for California
Privacy Information" on the subject line and in the body of
the message. We will provide the requested information to that
resident at the e-mail address in response.
1.4. Children's Online Privacy Protection Act (COPPA)
Our Web site is a general audience site that is not designed nor
intended to collect Personal Information from children under
the age of 18. RAPP does not knowingly collect or maintain any
Personal Information from children under the age of 18.
In addition, no part of this Web site is designed with the purpose
of attracting any person under age 18. To respect the privacy of
children and to comply with the Children's Online Privacy
Protection Act, children under the age of 18 should not provide
any Personal Information on this Web site. We ask that parents
supervise their children while online.
1.5. IP Address and Click-Stream Data Collection
RAPP may collect IP addresses and/or click-stream data for
market research, for purposes of system administration
and to report aggregate information. An IP address is a number
that is automatically assigned to a visitor's computer whenever
that visitor accesses the Internet. Our servers identify that
computer by its IP address. When the visitor requests Web
pages from our Web site, our servers log the IP address.
Click-stream data is information collected by our servers when a
visitor requests pages from our Web site. Click-stream data may
include such information as the page served, the time, the
source of the request, the type of browser making the request,
the preceding page view, and other such Non-personal Information.
When analyzed, this data helps us analyze how visitors arrive at
our Web site, what type of content is most popular, what type of
visitors in the aggregate are interested in particular kinds of
content, and the like.
1.6. Security
RAPP uses commercially reasonable efforts to store and maintain
Personal Information to protect it from loss, misuse, alternation
or destruction by any unauthorized party.
We exercise reasonable care to protect Personal Information.
This includes storing the Personal Information on our servers
behind a secured firewall and ensuring all transmissions
to other vendors use secure encryption technology. Unfortunately,
no data transmission over the Internet can be guaranteed to be 100%
secure. So while we strive to protect Personal Information,
we cannot guarantee the security of any information a client,
visitor, or third party transmit to us or receive from us. This is
especially true for information transmitted to us via e-mail.
We have no way of protecting that information until it reaches us.
Once we receive a transmission, we maintain physical, electronic,
and procedural safeguards to protect Personal Information.
Internally, we will limit access to Personal Information to
those persons who need the information to provide services to our
clients or maintain or service some of our products. These
persons are limited in number and are committed to our privacy
and security policies. We will review our security arrangements
from time to time, as we deem appropriate.
1.7. Links to Other Sites
Please be aware that we provide links to third-party sites as a
service to our visitors, and that we are not responsible for the
content or information collection practices of those sites.
Please note that these sites' privacy policies may differ from
those of RAPP. We encourage our clients and the public in general
to review and understand their privacy practices before providing
them with information.
1.8. Privacy Statement Revisions
A revised online privacy statement will only apply to data
collected subsequent to its effective date on this version of
our Web site. Any revisions will be posted at least 7 days prior
to its effective date.
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