Ring Partner ULC (“RingPartner,” “Company,” “we”, “us” or “our”) is primarily engaged in the business of connecting consumers with businesses that provide services a consumer is looking for, through lead generation.

We strive to build and maintain a relationship of trust with you. This Privacy Policy (“Privacy Policy”) describes how we collect, use, share and retain your Personal Information (as defined below) and how to exercise any rights you might have with respect this information. It governs information we collect through our website(s), microsite(s), mobile website(s), and mobile applications (collectively, “RingPartner Sites”) and information we collect, directly or indirectly, through any other means, including offline activities (collectively, “Services”). All Personal Information collected by us may be used, disclosed, shared, sold, transferred, or retained as described in this Privacy Policy.

Please read this Privacy Policy, which is part of our website Terms of Use (as defined below), before using RingPartner Sites and/or Services. If you do not agree with the Terms of Use and/or this Privacy Policy, you must refrain from using RingPartner Sites and/or Services. By using RingPartner Sites and/or Services you agree and provide your consent to our collection, sale, sharing, disclosure, use, and retention of your personal information consistent with the Terms of Use and this Privacy Policy, subject to your rights described below.

We encourage Consumers to read this Privacy Policy carefully before providing any Voluntarily Provided Personal Information on any RingPartner Site.

I. Definitions

Advertising Networks: Third Parties that serve interest-based advertising and generate related statistics.

Authorized Agent: A person or entity authorized by a Consumer under the California Privacy Act.

Automatically-Collected Personal Information: Information collected automatically through Data Technologies without Consumer action, not identifying a Consumer unless linked to Voluntarily-Provided Information.

California Privacy Act: Includes CCPA, CPRA, and Regulations.

Consumer: A natural person.

Consumer Requests: Specific online requests initiated by Consumers, containing Voluntarily Provided Personal Information.

Contractor: Third Party receiving Personal Information for business purposes under contract with RingPartner.

Data Technologies: Technologies like cookies and pixels used to gather information about actions on RingPartner Sites or Third-Party sites.

Geolocation Data: Any data that is derived from a device and that is used or intended to be used to locate a Consumer within a geographic area.

Interest-Based Advertising: Customized advertising based on Consumer online behavior predictions.

Online Behavioral Information: Data collected from a device about web viewing behaviors to predict preferences.

Personal Information: Information identifying or associated with a specific consumer or household, including Sensitive Personal Information and Employment-Related Information.

Precise Geolocation Data: Geolocation Data that is used or intended to be used to locate a Consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed by the regulations under the California Privacy Act.

Sensitive Personal Information: Includes various categories defined under the California Privacy Act.

Service Provider: Third Party processing Personal Information on behalf of RingPatner under contract.

TCPA: Telephone Consumer Protection Act of 1991.

Terms of Use: The terms and conditions governing your use of RingPartner Sites and that can be accessed at https://www.ringpartner.com/terms-and-conditions/.

Third Party: Person or entity not owned, operated, or controlled by RingPartner.

Voluntarily-Provided Personal Information: Personal Information collected from a Consumer as a result of the Consumer providing that information voluntarily to RingPartner or to a Third Party that sells or otherwise transfers the Personal Information to RingPartner.

II. Categories of Personal Information We Collect and Retention Periods

The tables below list the categories of Personal Information that (i) we collect; (ii) the purposes for which we collect, sell, share or disclose the Personal Information; and (iii) our expected retention periods for the Personal Information. 

The types of Personal Information we collect about you may vary based on how you use the RingPartner Sites and/or Services and the nature of your relationship with us. 

Personal Information Category	Nature or Type of Personal Information Collected	Business Purpose for Collecting Personal Information	Sold, Shared or Disclosed	Categories of Third Parties with/to who Shared/Sold/Disclosed	Retention Period or Criteria
Identifiers	First and last names (including aliases). Mobile and landline phone numbers. Email addresses. Postal/street addresses.	Fulfilling and processing Consumer Requests; Facilitating or fulfilling the information, products, or services Consumers requested;  Surveys Consumers for Marketing Purposes;  Market our referral services to consumers, including interest-based advertising; Marketing other companies’ products or services to Consumers.	Both	Third Parties that can provide the Consumer with the products, services or information that the Consumer has requested; Other digital marketing services companies that purchase Consumer Requests from RingPartner for sale, disclosure or transfer to such Third Party’s customers; Advertiser clients to assess the effectiveness of advertising campaigns we have provided for them; Third Party vendors and suppliers of products and services in which the Consumer has expressed an interest or about which a Consumer has requested information; Service Providers and Contractors; Third Parties that may wish to send the Consumer email, postal mail or SMS/text messages containing advertising or marketing materials regarding products or services that the Third Parties or their customers believe Consumers may find of interest; Courts, governmental.	5 years after your last use of Service  unless it is required by law to retain it for a longer period.
Internet or other similar network activity, including Geolocation Data	Cookie data Browsing history Search history IP address Device and browser information on a consumer’s interaction with a website, application, or advertisement; Geolocation Data (which may include Precise Geolocation Data; Precise Geolocation Data is geolocation data that is derived from a device, and that is used or intended to be used to locate a Consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed by regulations; Precise Geolocation Data constitutes Sensitive Personal Information under applicable law)	Services Improvement and account management	Both	Third Parties that can provide the Consumer with the products, services or information that the Consumer has requested; Other digital marketing services companies that purchase Consumer Requests from RingPartner for sale, disclosure or transfer to such Third Party’s customers; Advertiser clients to assess the effectiveness of advertising campaigns we have provided for them; Third Party vendors and suppliers of products and services in which the Consumer has expressed an interest or about which a Consumer has requested information; Service Providers and Contractors; Third Parties that may wish to send the Consumer email, postal mail or SMS/text messages containing advertising or marketing materials regarding products or services that the Third Parties or their customers believe Consumers may find of interest; Courts, governmental agencies and other Third Parties as required by applicable law, rule, regulation or order.	5 years after your last use of Service  unless it is required by law to retain it for a longer period.
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Providing Services to Consumers and fulfilling Consumer Requests Marketing and Advertising Services improvement and account management	Both	Third Parties that can provide the Consumer with the products, services or information that the Consumer has requested; Other digital marketing services companies that purchase Consumer Requests from RingPartner for sale, disclosure or transfer to such Third Party’s customers; Advertiser clients to assess the effectiveness of advertising campaigns we have provided for them; Third Party vendors and suppliers of products and services in which the Consumer has expressed an interest or about which a Consumer has requested information; Service Providers and Contractors; Third Parties that may wish to send the Consumer email, postal mail or SMS/text messages containing advertising or marketing materials regarding products or services that the Third Parties or their customers believe Consumers may find of interest; Courts, governmental agencies and other Third Parties as required by applicable law, rule, regulation or order.	5 years after your last use of Service  unless it is required by law to retain it for a longer period.

III. Categories of Sources From Which We Collect Personal Information

We collect Personal Information from the following categories of sources of Personal Information:

• Personal Information Voluntarily Provided by Consumers.You are not required to provide us your Personal Information to view RingPartner Websites unless you wish to voluntarily provide your Personal Information in order to be contacted by us, or other Third Party providing the products or services in which you are interested. If you choose not to provide the requested information, you may not be able to use some or all of the features of the RingPartner Sites or Services, and we may not be able to fulfill your requested interaction. We may also ask you to provide us with Personal Information when you communicate with us online or offline by telephone or texting, including in connection with customer surveys. Voluntarily-Provided Personal Information is also obtained from Third Parties that sell Consumer Requests to RingPartner where the Voluntarily-Provided Personal Information is collected by the Third Party from the Consumer on the Third Party’s website and sold to RingPartner to fulfill the Consumer’s Consumer Request by referral to a RingPartner customer.
  
• Personal Information Automatically Collected From Consumers.
  
• Third-Party Data Sources.We may collect Personal Information from third-party data sources such as advertising networks, marketing agencies, internet service providers, data brokers, operating systems and platforms, analytics firms, government agencies, and social networks.
  
• Mobile-specific information that we may collect.RingPartner collects information from a Consumer’s mobile devices such as hardware IDs and device type, the request type, your carrier, the Consumer’s carrier user ID, and the content of the Consumer’s request, which does not by itself identify the Consumer, though it may be unique or consist of or contain information that the Consumer may consider personal.
  
• Combined or Appended Personal Information and Personal Information from Third Parties. We may obtain from Third Parties Personal Information that they have collected and combine that information with Personal Information that that we have collected. The combined information may include information about the Consumer’s use of the RingPartner Sites; use of Third Party websites, devices and mobile applications; interests and preferences; and other information about the Consumer or the Consumer’s household.

IV. Purposes for Collecting, Selling, Sharing or Disclosing Personal Information.

We collect, sell, share or disclose Personal Information for the following business and commercial purposes:

Providing Our Services to Consumers and Fulfilling Consumer Requests 

  Collection of Voluntarily Provided Personal Information: RingPartner collects Voluntarily Provided Personal Information to fulfill Consumer Requests submitted through features or services requiring such information. This includes information submitted directly on RingPartner Sites or acquired from Third Parties, which is necessary to connect Consumers with home improvement professionals or other Third Parties. Consumer Requests may originate directly on RingPartner Sites or indirectly through Third Party websites, advertisements, or links placed by RingPartner on Third Party platforms.

The collected information is used to facilitate direct communication between Consumers and relevant service providers or Third Parties. It enables the delivery of requested products, services, or information, as well as the provision of advertising, marketing, or content relevant to Consumer interests. Consumers may submit requests directly on RingPartner Sites or indirectly via Third Party websites, advertisements, social media platforms, or email campaigns initiated by RingPartner or Third Parties. RingPartner ensures that all data handling practices comply with relevant privacy regulations and standards. Consent mechanisms are employed to manage the collection and use of Voluntarily Provided Personal Information, ensuring transparency and consumer control over their data.

Marketing and Advertising 

  Engagement in Marketing and Advertising: RingPartner utilizes Personal Information to inform Consumers about our services and deliver relevant advertising that may interest them. Automatically-Collected Personal Information generates Online Behavioral Information used for Interest-Based Advertising.

  Customization, Auditing, and Reporting: To enhance marketing programs, RingPartner collaborates with Advertising Networks. These networks utilize various Data Technologies to collect information across RingPartner Sites and Third-Party platforms. This enables Interest-Based Advertising and provides insights into the effectiveness of these marketing efforts. Advertising Networks also analyze this data to determine audience characteristics and preferences.

  Location-Based Customization: When Consumers use RingPartner Sites, geolocation information may be collected to offer location-specific content and services. This information may be shared with Third Parties to provide tailored advertising, services from local partners, or customize marketing based on the Consumer’s location. Geolocation data can range from precise GPS coordinates to general location information, depending on Consumer input and service requirements.

Service improvement

  Personalized Advertising and User Experience: We use Data Technologies to enhance your experience and provide personalized advertising, both on our websites and across other platforms. These technologies distinguish you from other users and may collect information about the web pages you visit, connecting information across different sources and devices. RingPartner and Third Parties may use cookies on our sites and other platforms to achieve this.

  User Understanding and Improvement: We utilize Third Party tracking services, facilitated by cookies, to better understand user behavior on RingPartner Sites. These cookies track visits, page views, and clickstream behavior, providing aggregated data to improve our sites. Anonymous, aggregated information from these cookies is shared with advertisers and Third Parties.

  Server Diagnosis and Site Administration: When you visit our sites, we collect your Internet Protocol (IP) address to diagnose server issues, administer the site, and track usage statistics. Information collected includes whether you arrived at our site via a link or advertisement on a Third Party site, aiding our understanding of user interests. We also gather data on your ISP (internet service provider), mobile carrier, and device type, used only in aggregate for reporting purposes.

  Enhanced User Experience with Analytics: Google Analytics collects anonymized data through Data Technologies, enabling us to understand user interactions on RingPartner Sites. This data, which may include non-personal Information or Voluntary-Provided Personal Information, helps us improve site functionality and user experience. Google Analytics uses first-party cookies and IP addresses to report website trends without identifying individual visitors.

V. Personal Information Use and Sharing

Use of Personal Information by RingPartner

Personal Information collected by RingPartner is used by RingPartner for the purposes described above, including to (i) improve the content or layout of the RingPartner Sites; (ii) improve user experience on RingPartner Sites; (iii) provide services requested by users of the RingPartner Sites; (iii) respond to questions, requests or complaints from Consumers; (iv) request feedback from Consumers; (v) develop new products and services; (vi) evaluate the effectiveness of the RingPartner Sites; (vii) contact Consumers for marketing purposes, including through email and SMS/text  marketing.

When a Consumer provides the Consumer’s email address as Voluntarily-Provided Information, we automatically include the Consumer’s name and email address and other Voluntarily-Provided Information in our marketing database to receive email communications from us that contain marketing, advertisements and content. We may collect information regarding the effectiveness of our email and other communications with the Consumer.

The Consumer’s submission of a Consumer Request constitutes the Consumer’s (i) affirmative consent and agreement to our Terms of Use and this Privacy Policy; and (ii) affirmative express written consent to sell/share the Consumer’s information with RingPartner and/or third parties, depending on the level of consent the Consumer provides when the Consumer shares Voluntarily-Provided Information; and authorize them to contact the Consumer through automated means (e.g., automatic telephone dialing system, text, artificial or pre-recorded messaging) for promotional marketing purposes at the phone number and email address the Consumer provided via live, pre-recorded, or auto dialed via telephone, mobile device (including SMS and MMS), and/or email, even if my number is currently listed on Federal or any state Do Not Call or Do Not Email. The Consumer also confirms the Consumer’s understanding that the foregoing consent is not a condition to purchase any product/service, and that the Consumer can revoke this consent at any time or opt-out of SMS messages by replying STOP. The acknowledges that the Consumer’s carrier’s message and data rates may apply.

Categories of Third Parties to Which We Sell, Share or Disclose Personal Information 

We may sell, share, disclose, or transfer Personal Information to Third Parties under the following circumstances: 

• To Third Parties that can provide the Consumer with the products, services or information that the Consumer has requested;
• To our advertiser clients to assess the effectiveness of advertising campaigns we have provided for them;
• To other digital marketing services companies that purchase Consumer Requests from RingPartner for sale, disclosure or transfer to such Third Party’s customers;
• To Service Providers and Contractors;
• To Third Parties who provide us appended Personal Information;  
• To Third Party vendors and suppliers of products and services in which the Consumer has expressed an interest or about which a Consumer has requested information; 
• To Third Parties that may wish to send the Consumer email, postal mail or SMS/text messages containing advertising or marketing materials regarding products or services that the Third Parties or their customers believe Consumers may find of interest; and
• To courts, governmental agencies and other Third Parties as required by applicable law, rule, regulation or order.

These Third Parties may use your Personal Information for their normal business purposes, including marketing, customer service, fulfillment, and related purposes.

We may aggregate Personal Information from all of our users and provide that information in the aggregate to vehicle dealers, vehicle manufacturers, advertisers and other Third Parties for marketing and promotional purposes. However, if we do so, that aggregated information will be anonymized so as not to be personally-identifiable.

Co-Branded Websites 

We sometimes partner with RingPartner’s affiliated companies whose products or offerings may be of interest to you. We strive to be transparent by co-branding our Sites and clearly posting a message if you leave our Sites and navigate to another. When you visit or use a part of any Site that is co-branded or that is a part of a joint promotion involving RingPartner’s affiliate (each a “Co-Branded Party”), you are providing and consenting to provide your Personal Information and any other information collected by any Co-Branded Party to RingPartner’s affiliate.

Service Providers and Contractors

Categories of Service Providers or Contractors that may receive Personal Information from us or on our behalf or to which we make available Personal Information include: 

• Fulfillment and account servicing vendors that help us provide products, services and information to you, service your account or benefits, collect survey responses, and support our e-commerce services; 
• Marketing and communications vendors that help us market our products/services to you, conduct promotions, events, surveys and other outreach campaigns; 
• Research and development vendors that help us develop and improve our products and services; 
• Data and business analytics vendors that help us collect, analyze, and improve the accuracy of our data (including Personal Information); 
• IT and network administration vendors that provide services such as data storage and management, website hosting, and data security; 
• Professional service firms that provide accounting, legal, and other professional services; and 
• General service providers that help us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction. 

Legal Matters

RingPartner will cooperate with legal authorities and may in some circumstances be required to disclose Personal Information in response to requests from law enforcement or other governmental agencies, or in response to a subpoena or other legal process. We can also share information about you if we believe we must in order to (i) prevent a violation of the law; (ii) protect or defend our interests and the legal rights or property of RingPartner and our affiliates; (iii) protect the rights, interests, safety and security of users of the RingPartner Sites or members of the public; (iv) protect against fraud or for risk management purposes; or (v) comply with prudent legal practice as we may determine, and with applicable law or legal process. We may also share Personal Information in the course of legal proceedings if we are legally required to do so, if we reasonably believe that doing so may mitigate our liability, or if doing so will assist us in enforcing our legal rights.

Business Transfers and Other Transactions

Information about our users and the RingPartner Sites is a business asset of RingPartner. As we continue to develop our business, we might sell or buy websites, subsidiaries or business units. In such transactions, Personal Information generally is one of the transferred business assets. Also, in the event that RingPartner or substantially all of its assets are acquired, Personal Information will of course be one of the transferred assets. In addition, Personal Information will be disclosed as part of any creation of a separate business to provide an RingPartner Site, or to provide other services or fulfill products; debt financing, sale or pledge of company assets, or insolvency, bankruptcy or receivership. We will make reasonable efforts to ensure that the acquirer of our users’ Personal Information respects the provisions of this Policy, although this may not be possible in certain legal settings (such as bankruptcy). 

VI. Your Choices Regarding Your Personal Information 

You may limit and control the Personal Information collected by us in a number of ways.  Note that California residents may have additional limitation and control rights that are described in the section of this Privacy Policy entitled “Notice to California Residents Regarding Your California Privacy Rights.”

Voluntarily-Provided Personal Information

You are not required to provide any Voluntarily-Provided Personal Information to visit or use the RingPartner Sites. You may elect to not provide Voluntarily-Provided Personal Information for any purpose. However, in doing so, you may not be able to use all features provided by the RingPartner Sites or all services provided by RingPartner. For example, if you do not provide the Voluntarily-Provided Information required to submit a Consumer Request, you will not be able to submit Consumer Requests, and RingPartner and other Third Party service and product providers will not be able to contact you to provide you the products, services or information in which you may be interested. You may also choose not to participate in surveys.

Opting Out of Email Marketing

We provide our users with the ability to choose whether to receive email communications from us and to permit their Personal Information to be disclosed to Third Parties for marketing or related purposes. If a Consumer does not wish to receive promotional and marketing communications from us, the Consumer may do so (i) if the Consumer received a promotional or marketing email from us, by following the link for that purpose located at the bottom of the email, or (ii) by sending a request to us by contacting our Consumer Care Department as provided under the section of this Privacy Policy entitled “Contact Us” below. However, withdrawing a Consumer’s consent will not affect the use of the Consumer’s Personal Information by Third Parties that previously received the Consumer’s Personal Information to continue to send communications to the Consumer and otherwise use the Consumer’s Personal Information. 

In addition, we provide you the opportunity to indicate your preferences as to what types of offerings of products or services you wish to receive from Third Parties or, subject to the exceptions below, to opt-out of disclosures to those Third Parties altogether. You may update your preferences at any time by contacting us at privacy@ringpartner.com. Those Third Parties who receive your Personal Information prior to your opt-out will remain able to send you communications, subject to their privacy policies and practices. To opt-out from receiving third party emails, you must contact those third parties directly. 

Even if a Consumer decides not to receive offers or other product or service information, RingPartner and other product and services providers, fulfillment third-parties and other referral services with which RingPartner has relationships, may use a phone number, mailing address or email address that the Consumer has provided to contact the Consumer regarding a Consumer Request that the Consumer submitted. Additionally, phone numbers and email addresses may be used to conduct customer surveys regarding individual experiences with RingPartner, or other product and services providers. Phone numbers and email addresses are made available only to RingPartner, its affiliates and other referral services, fulfillment third parties and other referral services who receive a Consumer Request. 

If a Consumer requests to opt-out of receiving emails from us and then subsequently submits a Consumer Request (either directly or submitted through a Third-Party and are referred to us), this action will reinstate the relationship with us and we will use the Consumer’s Personal Information as set forth herein, unless the Consumer subsequently requests to opt-out again. Each time a Consumer submits a Consumer Request, this process will restart.

Automatically-Collected Personal Information

Opting Out of Data Technologies.

Consumers have a number of choices regarding certain Data Technologies.

Most web browsers automatically accept cookies, but a Consumer can usually modify the Consumer’s browser’s setting to decline cookies if the Consumer prefers. Consumers have the ability to accept or decline cookies by modifying the Consumer’s browser settings, and our websites are viewable even if the Consumer disables the cookie function on the Consumer’s browser. However, if a Consumer disables cookies, note that certain features may not function properly or at all as a result, and some advanced and customized features or offerings will not be available to the Consumer, including personalization features.

If a Consumer prefers not to accept cookies, the Consumer should consult documentation for the Consumer’s browser or device for more information. Most browsers will explain how to view and disable cookies under the help portion of the toolbar or notify the Consumer when the Consumer receives a new cookie. Use of third party cookies is subject to the privacy policies and opt-out procedures of these third parties and not RingPartner’s policy and procedures. Please click here  www.networkadvertising.org in order to learn more about the data and information collection and use practices of some of the third parties for which we set cookies on RingPartner Websites or for which we enable to set their own cookies. Please click here  http://www.networkadvertising.org/managing/opt_out.asp in order to learn more about the “opt-out” procedures of some of these third parties. At times, not all of the third parties for which we set cookies on RingPartner Websites or for which we enable to set their own cookies are included in the preceding link to opt-out from these cookies. Should you wish to opt-out of these cookies, a Consumer will need to access the third party’s website to determine their opt-out procedure. 

A Consumer may also render some web beacons unusable by rejecting their associated cookies and disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on’s settings or opting out at the website of the technology provider.

A Consumer may refuse to accept a cookie from us on mobile devices by adjusting the use of advertising identifiers through the settings on the Consumer’s computer or device. A Consumer’s mobile device may also have settings that allow the Consumer to prevent sharing Geolocation Data with us. Consumer’s should consult their mobile device’s settings or help documentation for more information about exercising these options.

Consumers can opt out of delivery of interest-based advertising to the Consumer by multiple companies by visiting www.aboutads.info/choices, www.networkadvertising.org/managing/opt_out.asp and www.evidon.com. Please note that even if a Consumer opts out, the Consumer will continue to receive advertisements, but the advertisements will not be tailored to the Consumer’s specific interests.

RingPartner uses Google Analytics, which helps RingPartner better understand its audience and target communications and advertisements based on demographic or interest-based information. Consumers may learn more about opting out of certain Google advertising initiatives and to install Google Analytics Opt-out Browser Add-on https://tools.google.com/dlpage/gaoptout. Please note that Consumers may still receive advertising even after opting out, but that advertising may not be tailored to the Consumer or the Consumer’s interests.

Trackable Telephone Numbers

If a Consumer does not want to have information collected through the Consumer’s use of a trackable telephone number, the Consumer may choose to not call the service provider to which the number is assigned by using the trackable phone number displayed on RingPartner Sites.

Response to Opt-Out Preference Signals

As of the effective date of this Privacy Policy, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to such signals or to other mechanisms that provide the ability to exercise choice regarding the collection of Personal Information regarding your online activities over time and across third party websites or online services.

Revocation of TCPA Consent and Opting Out of Automated Calls and Text Messaging

You may revoke your consent and opt-out from receiving calls or text messages at any time. You may opt-out of text messages by replying STOP to any text message you receive or follow other opt-out instructions included with the text message. You acknowledge and agree that you may receive a text message confirming your opt-out. To opt-out of telephone calls from RingPartner (but not text messages), contact our team as provided below under “Contact Us.” To opt-out of receiving telephone calls or texts from Third Parties, please contact the Third Party directly. To obtain assistance from our team  with respect to text messaging, contact our team as provided below under “Contact Us.”

VII. Children and Minors

RingPartner Sites are not directed to minors under the age of 16, including both children under the age of 13 and children at least 13 and less than 16 years of age (collectively, “Minors under the age of 16”). We do not intend, and RingPartner Sites are not designed, to collect from, sell or share Personal Information of Minors under the age of 16. We do not knowingly collect, sell, or share Personal Information of Minors under age 16 and do not have actual knowledge that we sell or share Personal Information of Minors under age 16. If you are under 16 years old, you should not provide Personal Information to any RingPartner Website. Should we obtain actual knowledge that we have collected or received Personal Information from a Minor under the age of 16 without the verifiable consent of a person that we have determined by reasonable methods to be the minor’s a parent or guardian (if a minor is under 13 years of age), or the minors’ consent (if a minor is at least 13 and less than 16 years of age), we will delete that information. If you believe we might have any information from or about a Minor under the age of 16, please contact our team as specified in the ” Contact Us” section below. We do not sell or share Personal Information without the affirmative consents required by the California Privacy Act if we obtain actual knowledge that we collected or maintain Personal Information from Minors under the age of 16. 

VIII. Third Party Privacy Policies, Terms of Use, and Marketing Consents

A Consumer’s Personal Information is collected by a Third Party in several ways: when the Consumer initially provides Personal Information directly on a Third Party site rather than on a RingPartner Site; when the Consumer clicks on a link to a Third Party site from RingPartner Site, including Third Party advertisements; when we sell, share, disclose, or transfer the Consumer’s Personal Information to a Third Party, such as when selling a Consumer Request to a home improvement professional; when RingPartner allows a Third Party to place cookies or other Data Technologies on its site; and when RingPartner permits a Third Party to offer products and services on its sites in a “framed” format or by direct linking, with clear identification of the Third Party.

When a Consumer’s Personal Information is collected by a Third Party, the Third Party’s collection, use, sale, sharing, disclosure or other transfer the Consumer’s Personal Information is governed by the Third Party’s privacy policy and terms of use. In addition, the Third Party is responsible for obtaining the Consumer’s consent under the TCPA if the Personal Information collected includes your telephone number (landline or mobile). Because we do not control the activities of Third Parties, we do not accept or assume responsibility for any collection, use, storage, sale, sharing, disclosure or other transfer of Personal Information by such Third Parties or with respect to obtaining your consumer  consent, and we cannot represent or guarantee that they will adhere to the same privacy practices or procedures as RingPartner. We encourage Consumer’s to review the privacy policies and terms of use of any Third Parties to which a Consumer provides Personal Information or from which a Consumer requests information, products or services.

IX. Security Procedures and Practices 

RingPartner has implemented and maintains reasonable administrative, technical, personnel, and physical security procedures and practices appropriate to the nature of the Personal Information and designed to protect the Personal Information stored in our systems against unauthorized or illegal access, destruction, use, modification, or disclosure. Although RingPartner has endeavored to create a secure and reliable networks, servers and databases that we operate or that are operated on our behalf, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security and cannot guarantee protection of all information against interception, misappropriation, misuse, or alteration, or that information may not be disclosed or accessed by accidental circumstances or by the unauthorized acts of others.

X. Changes or Revisions to This Policy

We reserve the right to change this Privacy Policy at any time without prior individual notice. Any changes to our Privacy Policy will be posted at this URL, so be sure to check back often and consult the last updated version. Your continued use of RingPartner Sites and Services following notice of such changes will be conclusively deemed acceptance of any changes to this Privacy Policy. You agree that posting of changes to this Privacy Policy constitutes reasonable and sufficient notice. At all times, you are bound by the then-current version of the Privacy Policy and all applicable laws. We highly recommend that you review this Privacy Policy from time to time. Any change to this Privacy Policy that materially affects your rights to your Personal Information will not take effect until 30 days after notice of such change is posted on the site, during which time you may notify us that you do not accept such change. If you do not accept such change, then you must immediately discontinue use of RingPartner Sites. Your continued use of RingPartner Sites after such 30-day period will mean that you accept such changes. If we make material changes that will affect Personal Information we have already collected from you prior to the changes going into effect, we will make reasonable efforts to notify you of these material changes and to give you the opportunity to opt-out and not allow us to use your Personal Information in the manner allowed by the changes.

XI. Disputes

Your access and use of RingPartner Sites and any dispute regarding privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the law of the State of California .

XII. Updating or Correcting Your Personal Information. 

To update your Personal Information, you must submit a request by contacting our team as provided under the section of this Privacy Policy entitled “Contact Us” below. Note that California residents should also review the additional requirements applicable to California residents in the section of this Privacy Policy entitled “Notice to California Residents Regarding Your California Privacy Rights.”

XIII. Contact Us

If you have any questions or need help or assistance regarding privacy, security, opting-out of email or text communications, your email and marketing preferences, or understanding how your Personal Information is being used, please contact our team by email at privacy@ringpartner.com or by calling via our toll-free number at 1-877-556-1204.  Note that California residents should also review the additional requirements applicable to California residents in the section of this Privacy Policy entitled “Notice to California Residents Regarding Your California Privacy Rights.”

Notice to California Residents Regarding Your California Privacy Rights

The California Privacy Act provides eligible California residents with specific rights with respect to our collection, retention, use, selling, sharing and disclosure of Personal Information. This California Privacy Rights section supplements this Privacy Policy and applies solely to eligible residents of California. Any terms not defined in this section have the same meaning as defined in the California Privacy Act. 

Summary of California Privacy Rights Act

Right to Request and Obtain Information Regarding Personal Information (“Right to Know”). The California Privacy Act entitles California residents to request information about the Consumer’s Personal Information collected by the business in the 12 months preceding the request and concerning the categories of Personal Information that the business has collected about the Consumer; the categories of sources from which the Personal Information was collected; the business or commercial purpose for collecting, selling or sharing the Personal Information; the categories of third parties with whom the business discloses Personal Information; and the specific pieces of Personal Information that a business has collected about the individual Consumer. If the business also sells or shares the Consumer’s Personal Information or discloses it for a business purpose, in addition to the foregoing information, the consumer has the right to obtain the categories of Personal Information that the business sold or shared about the consumer in the 12 months preceding the request and the categories of third parties to whom the Consumer’s Personal Information was sold or shared (by category or categories of Personal Information for each third party to whom the Personal Information was sold or shared); and the categories of Personal Information that the business disclosed about the Consumer for a business purpose. Upon request by the Consumer, we may be required to provide the foregoing information for a period beyond the 12-month period unless doing so proves impossible or would involve disproportionate effort. This extended reporting period shall only apply to Personal Information collected on or after January 2, 2022. California residents who wish to request the foregoing information in compliance with the California Privacy Act should submit their requests as provided below under the section entitled “Submission of Requests To Exercise California Privacy Rights–Requests to Know, Requests to Delete and Requests to Correct” below.

Right to Have Personal Information Deleted (“Right to Delete”).  The California Privacy Act entitles California residents to request that a business delete all Personal Information about the Consumer that the business has collected, subject to certain exceptions set forth in the California Privacy Act.  California residents who wish to request deletion of their Personal Information in compliance with the California Privacy Act should submit their requests as provided below under the section entitled “Submission of Requests To Exercise California Privacy Rights–Requests to Know, Requests to Delete and Requests to Correct” below.

Right to Have Inaccurate Personal Information Corrected (“Right to Correct”).  The California Privacy Act entitles California residents to request that a business that maintains inaccurate Personal Information about the Consumer to use commercially reasonable efforts to correct that inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. California residents who wish to exercise the foregoing right should submit their requests as provided below under the section entitled “Submission of Requests To Exercise California Privacy Rights– Requests to Know, Requests to Delete and Requests to Correct” below.

Right to Opt-out From the Sale or Sharing of Your Personal Information to Third Parties (“Right to Opt-Out of Sale/Sharing”).  The California Privacy Act entitles California residents to direct that a business that sells or shares Personal Information about the Consumer to third parties not to sell and/or share the Consumer’s Personal Information. California residents who wish to exercise this right in compliance with the California Privacy Act should submit their requests as provided below under the section entitled “Submission of Requests To Exercise California Privacy Rights–Requests to Opt-Out of Sale/Sharing” below.

Right to Have the Use and Disclosure of Sensitive Personal Information Limited (“Right to Limit). The California Privacy Act entitles California residents to direct that a business that collects Sensitive Personal Information about the Consumer to limit its use of the Consumer’s Sensitive Personal Information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests those goods or services, except that this Right to Limit is not applicable to certain such uses permitted by the California Privacy Act. California residents who wish to exercise the foregoing right should submit their requests as provided below under the section entitled “Submission of Requests To Exercise California Privacy Rights–Requests to Limit  below. 

No Discrimination Against Persons Exercising Rights Under the California Privacy Act. RingPartner will not discriminate against any Consumer because the Consumer exercised any of the Consumer’s rights under the California Privacy Act. Unless permitted by applicable law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
• Retaliate against an employee, applicant for employment, or independent contractor.

Information Regarding Collection and Sale of Personal Information and Requests. The following information regarding Personal Information collected and sold/shared by RingPartner and Consumer requests to exercise various rights under the California Privacy Act can be accessed by clicking here:

• Metrics for the immediately preceding calendar year regarding the following:
  • The number of requests to delete Personal Information that we received, compiled with in whole or in part, and denied during the calendar year.
  • The number of requests to correct Personal Information that we received, complied with in whole or in part, and denied during the calendar year.
  • The number of requests to know Personal Information that we received, complied with in whole or in part, and denied during the calendar year.
  • The number of requests to opt-out of sale/sharing Personal Information that we received, compiled with in whole or in part, and denied during the calendar year.
  • The number of requests to limit the use or disclosure of Sensitive Personal Information that we received, compiled with in whole or in part, and denied during the calendar year.
  • The median number of days within which we substantively responded to requests to delete, requests to know, requests to opt-out of sale/sharing, and requests to limit.

Other California Privacy Rights

Right to Request Information Regarding Sharing of Personal Information With Third Parties for Direct Marketing Purposes. The California “Shine the Light Law” (Cal. Civil Code Section 1798.83) entitles California residents to request information concerning whether a business has disclosed certain Personal Information about the consumer during the immediately preceding calendar year to any third parties for the third parties’ direct marketing purposes. California residents who wish to request further information in compliance with this law or have questions or concerns about our privacy practices and policies may contact our Consumer Care Department as specified in the section entitled “How to Contact Us Regarding This Privacy Policy and Your California Privacy Rights, below.

Children and Minors. Section 22581 of the California Business and Professions Code permits a resident of California who is both under the age of 18 and a registered user of any site on which this Privacy Policy is posted to request and obtain removal of content that the user has publicly posted. Please be aware that such requests do not ensure the complete removal of the content posted, and there may be circumstances in which the law does not require or allow removal, even if requested. To request removal of content under Section 22581 of the California Business and Professions Code, please contact us as specified in the section entitled “How to Contact Us Regarding This Privacy Policy and Your California Privacy Rights below.

Submission of Requests To Exercise California Privacy Rights

Requests to Know, Requests to Delete and Requests to Correct

To exercise your Right to Know, Right to Delete or Right to Correct, you must submit a verifiable request (as defined by the California Privacy Act) to our team by email at privacy@ringpartner.com, by calling via our toll-free number at 1-877-556-1204, or by accessing our request form online at https://privacyportal.onetrust.com/webform/27aa5d67-8136-4a08-ae4b-9860992e2375/58a65c88-beb1-4ff6-9801-72f97ef52616.

A verifiable consumer request must:

• Provide sufficient information that allows us to verify, using commercially reasonable methods, that you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• For Requests to Delete, we may use a two-step process for online Requests to Delete where the Consumer must first submit the request and then separately confirm that the Consumer wants to delete the Consumer’s Personal Information.

The California Privacy Act requires that we verify the identity of the requesting Consumer to a reasonable degree of certainty or reasonably high degree of certainty depending on the type of request and the Personal Information about the requesting Consumer maintained by us, as well as the sensitivity of the Personal Information and the risk of harm to the Consumer posed by unauthorized deletion, access or correction.  We cannot comply with your Request to Know, Request to Delete or Request to Correct if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

No later than ten (10) business days after receiving a Request to Know, Request to Delete, or Request to Correct, we will confirm receipt of your request and provide information about how we will process the request, including information regarding our verification process and when you should get a response to your request. We will respond to a Request to Know, Request to Delete or Request to Correct within 45 calendar days of receipt of a request.  If we require more time (up to an additional 45 calendar days, for a maximum total of 90 calendar days) to respond, we will notify you of the reason and extension period. If we are unable to comply with or deny a request, the response we provide you an explanation of the reasons why we cannot comply with or denied the request.

We will deliver our written response to a Request to Know information by mail or electronically, at your option.

We are not obligated to provide a Consumer the information requested in response to a Request to Know more than twice within a 12-month period.

With respect to Requests to Correct, if we deny a Request to Correct because we have determined that the contested Personal Information is more likely than not accurate based on the totality of the circumstances, we may elect to delete the contested Personal Information if the deletion does not negatively impact the Consumer or the Consumer consents to the deletion.

Requests to Opt-Out of Sale/Sharing and Requests to Limit

To exercise your Right to Opt-Out of Sale/Sharing or Right to Limit you must submit a request to our team by email at privacy@ringpartner.com, or by calling via our toll-free number at 1-877-556-1204.

We will act upon your request within fifteen (15) business days after receipt of your request. If we determine that your Request to Opt-Out of Sale/Sharing or Request to Limit is fraudulent and deny the request, we will inform the requesting Consumer of that decision and provide an explanation of why we believe the request is fraudulent. 

Requests to Opt-In To Sale/Sharing

A Consumer who has exercised the Consumer’s right to opt-out from the sale and/or share of the Consumer’s Personal Information, may change the Consumer’s mind and opt back in to personal information sales or sharing at any time by submitting a request to our team by email at privacy@ringpartner.com, by calling via our toll-free number at 1-877-556-1204, or by accessing our request form online at https://privacyportal.onetrust.com/webform/27aa5d67-8136-4a08-ae4b-9860992e2375/58a65c88-beb1-4ff6-9801-72f97ef52616. A two-step process will be used whereby the Consumer must first clearly submit the request to opt-in, and then second, separately confirm the Consumer’s choice to opt-in.

Authorized Agents

A request that must be verified may be submitted by an Authorized Agent. If a request is submitted by an Authorized Agent on your behalf, we will require that (i) the Authorized Agent to provide proof that the Consumer gave the Authorized Agent signed permission to submit the request; and (ii) the Consumer verify the Consumer’s own identity directly with us or directly confirms with us that the Consumer provided the Authorized Agent permission to submit the request; provided that the foregoing two requirements shall not apply to an Authorized Agent who has been given a power of attorney by the Consumer pursuant to California Probate Code sections 4121-4130.If a parent or guardian is submitting a request on behalf of a minor under the age of 13, the parent or guardian must submit verifiable proof and we must determine by reasonable methods that they are the parent or guardian of the minor. 

Request Fees and Denial of Requests

We do not charge a fee to verify, process or respond to requests; provided that if requests are manifestly unfounded or excessive, including by reason of them being repetitive, we may charge a reasonable fee with respect to responding to the request or refuse to act on the request.  If we determine that a request is manifestly unfounded or excessive, we provide you with a cost estimate before completing your request or notify you of the reason we decided to refuse to act on the request.

How to Contact Us Regarding This Privacy Policy and Your California Privacy Rights

If you have any questions regarding this Privacy Policy, your rights under the California Privacy Act (e.g., Right to Know, Right to Delete, Right to Correct, Right to Opt-Out of Sale/Sharing,  Right to Limit) or the other California privacy rights summarize above, or the process to submit requests to exercise your California Privacy Rights, please contact our team by email at privacy@ringpartner.com or by calling via our toll-free number at 1-877-556-1204.