Privacy Policy

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Updated May 21, 2022   

Information you provide us directly:
We ask for certain information such as your username, real name, address, phone number and e-mail address when you register for a RampedUp account, or if you correspond with us. We use this information to operate, maintain, and provide to you the features and functionality of the Service.

Information we may receive from third parties:
We may receive information about you from third parties. For example, if you access our websites or Service through a third-party connection or log-in. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the RampedUp Service. You may also unlink your third party account from the Service by adjusting your settings on the third party service.

How do we collect B2B data?
RampedUp provides Non HR business data that we get from a number of sources; a) Our research team that sources information from publicly available information, b) Users provide data about themselves or other companies & people, c) We license data from other data providers. Our data is not considered sensitive or protected by HIPPA / FCRA.

Analytics information:
We may directly collect analytics data, or use third-party analytics tools and services, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.

Cookies information:
When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets RampedUp help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

Log file information:
Log file information is automatically reported by your browser or mobile device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

Device identifiers:
When you access the Service by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by RampedUp. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

Commercial and marketing communications:
We use the information we collect or receive, such as your email address, to communicate directly with you. We may send you emails containing newsletters, promotions, and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Service-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).

What happens in the event of a change of control:
We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, User Content and other user information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.

Instances where we are required to share your information:
RampedUp will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security, quality or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of RampedUp, our Users, or others.

What happens in the event of a data breach:

RampedUp cares about the security of your information, and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. RampedUp utilizes generally-accepted security measures (such as encryption) to protect against the misuse or unauthorized access to our platform. Lastly, we partner with Amazon Web Services (AWS) with strategically placed and limited number of access points to the cloud to allow for a more comprehensive monitoring of inbound and outbound communications and network traffic. However, individuals who may have been impacted by the breach will be notified by RampedUp. 

How We Store and Protect Your Information

Storage and Processing:
We can create an instance of RampedUp that is hosted on European soil provided that we are expressly asked to do so by the client.  Without this notification, your information collected through the Service may be stored and processed in the United States or any other country in which RampedUp or its subsidiaries, affiliates, or service providers maintain facilities. RampedUp may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

Keeping your information safe:
RampedUp cares about the security of your information, and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from RampedUp, at all times. Your privacy settings may also be affected by changes to the functionality of third party sites and services that you add to the RampedUp Service, such as marketing or sales tools. RampedUp is not responsible for the functionality or security measures of any third party.

Compromise of information:
In the event that any information under our control is compromised as a result of a breach of security, RampedUp will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

We make every effort to promptly process all unsubscribe requests. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at contact@RampedUp.io

How long we keep your private profile information:
Following termination of your User account, RampedUp may retain your private profile information for a commercially reasonable time for backup, archival, or audit purposes. For the avoidance of doubt, any information that you choose to make public on the service may not be removable.

Privacy Shield Framework

RampedUp commits to subject to the Privacy Shields’ Principles all Personal Data received by RampedUp in the U.S. from European Union member countries and Switzerland in reliance on the respective Privacy Shield framework. RampedUp can be found on the U.S. Department of Commerce list of companies in compliance with the US – EU Privacy Shield Framework.  Reference Number: a2zt0000000PL5uAAG.

RampedUp complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/

Individuals may have the right to limit the use and disclosure of their personal information as required by the Privacy Shield’s Principles, such as whether your personal information is disclosed to a third party or used for purposes materially different from the purpose for which the personal information was originally collected or subsequently authorized by you. If you wish to limit the use and disclosure of personal information in accordance with the Privacy Shield Principles, please contact us at contact@rampedup.io.

In compliance with the Privacy Shield Principles, RampedUp commits to resolve complaints about our collection or use of your personal information.  RampedUp is committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.

RampedUp is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and under certain conditions, for individuals to invoke binding arbitration.  RampedUp may also have liability in cases of onward transfers to third parties. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Scott Miller at scott.miller@rampedup.io.

GDPR Considerations

As explained above, without notification from our customer to move their hosting to European soil, we process data in various ways depending upon your use of our sites and services. We process personal data on the following legal bases: (1) publicly available on web search engines  (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedom related to data privacy. RampedUp’s business data is within RampedUp’s legitimate interests to organize and make available business contact information given the limited impact of this data on an individual’s private life and that this information, unlike personal contact details, is publicly available.

RampedUp uses data from publicly available sources including social media, job posting, career sites, corporate websites, and press releases.  We provide the source data on our contact records when available. RampedUp uses information made publicly available by the individual or by their company on their behalf – if an individual would like to be removed from our database they may notify us via our privacy portal.

As a data controller, opt-in consent cannot be transferred to our customers and must be obtained by the customers themselves.  Our contact data is updated continuously and is removed from our database after a period of 2 years.

Services we provide

RampedUp helps organizations keep their "opted-in" professional contact data updated to comply with international regulatory organizations.  We also help organizations identify professionals within their own Legitimate Business Interests for business purposes.

The type of data we collect
RampedUp collects publicly available information such as employer, employment dates, title of employment, location of employment, address of employer, phone number, and email address.  We associate this information with the source of the data such as a social profile, corporate website, or press release. 

THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA) AND YOUR RIGHTS

On June 28, 2018, California signed into law the California Consumer Privacy Act (CCPA) of 2018, which grants California residents new rights regarding the collection and disclosure of information about them. Effective January 1, 2020, companies will be required to provide California residents with access to the categories of personal information collected about them, the specific pieces of personal information collected about them and categories of sources, and the types of third parties with whom the personal information was shared. CCPA also grants CA residents a right to delete their information and a right to opt out of future data sales and sharing. California residents are able to request access to a summary of any marketing data we have in our databases about you as an individual. 

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of RampedUp, LLC and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” “residents” or “you”).  We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice. Information We Collect We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

· Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.
· Personal information categories listed in the California Customer Records statute: A name, address, telephone number, email address and website. Some personal information included in this category may overlap with other categories.
· Protected classification characteristics under California or Federal law. Gender, in terms of salutation or gender only, Mr., Mrs., MS, Male or Female etc.

Information found on the public web

Professional or Employment- related Information – RampedUp may process, collect or ‘sell’ information relating to a Californian’s resident’s job title, including name, email address, or corporate address, phone number and information about what you may be responsible for purchasing in your role, such as ‘computer software.’ The categories of entities to which we may sell that information are, generally, business to business services providers, advertising networks and data platforms, retailers of business products and services, data compilers and resellers, 

Use of Personal Information:  Our purposes in collecting and using personal information We may use or disclose the personal information we collect for one or more of the following business purposes:

· To provide you with information, products or services that you request from us.
· To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
· To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
· To improve our website and present its contents to you.
· To service contracts with our clients to help them fulfil their marketing programs to develop new business and service existing business
· For testing, research, analysis and product development.

To provide our data and data marketing services, which we generally describe below:

Our Purposes for collecting, using and sharing Personal Information Data marketing services, for example:

Generally, creating data marketing tools and products for our marketer clients, as more fully described in our Privacy Policy (and on our websites). This includes our provision of datasets, data “appends” (connecting data across datasets), data “scoring” (providing inferences about potential consumer behavior), data hygiene services (helping customers to evaluate, validate and correct personal information they hold.

Helping our clients identify and understand their consumers better, by providing insights about them and managing loyalty programs, as well as providing financial and other scoring products. Assisting our clients through our Services to provide their current and prospective customers with better service, improved offerings, and special promotions, for instance, advising on which current or prospective customers are most likely to be interested (or disinterested) in certain offers.

Online targeting, for example:
Creating or helping to create defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., technology professionals). When we do this, we work with a data partner that “matches” our or other Information through de-identification techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels.

Additional marketing services, for example (which may overlap with “data marketing services” above):
Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing, including by providing customer insights.
Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.
Analyzing and optimizing our clients’ (or their service providers’) proprietary databases, to assist in our client’s marketing campaigns to reach new customers.

Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. Access to Specific Information and Data Portability Rights Right To Know If you are a California resident, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (which will require us to obtain certain information from you for purposes of verification), we will disclose to you:

· The categories of personal information we collected about you.
· The categories of sources for the personal information we collected about you.
· Our business or commercial purpose for collecting or selling that personal information.
· The categories of third parties with whom we share that personal information.
· The specific pieces of personal information we collected about you (also called a data portability request).
· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights 

You also have the right as a California (and Vermont) resident to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.  (Note that most of the information in our files is not obtained directly from consumers, so this deletion right may not apply.) We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising your right to opt-out of the sale of your personal information California (and Vermont) residents may opt out of the “sale” of their personal information. California (and Vermont) law broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.” Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in this Addendum. If you would like to opt out, and are a resident of California (or Vermont) and wish to contact us; please use our dedicated toll-free number (888) 278-3433 or form found below. 

DO NOT SELL MY INFORMATION
RampedUp will provide Individuals or Organizations the data we have associated with them by completing this form. They may ask to limit or eliminate the data from within our database and any organization we have shared the data with over a period of time. 

Each written request must be submitted by completing the online form and authenticated via email conformation. RampedUp requires authorized agents to submit proof that they have been authorized by the subject to act on the subject's behalf. 

Both a subject and an authorized agent must submit and authenticate written requests through the online form as a security measure to detect fraudulent activity and prevent the unauthorized access to or deletion of a consumer’s personal information.  If RampedUp has a good-faith, reasonable, and documented belief that a written request to opt-out is fraudulent, malicious, or an attempt to obtain personal information without the consent of the data subject, we have legal reason to deny the request and report the effort to the appropriate authorities. 

Response Timing  We will confirm receipt of request within 10 days and respond to a verifiable consumer request within 45 days of its receipt.  If we require more time, up to 90 days, we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  the  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Non-Discrimination We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.

Vermont Data Broker Registration Number: 0409326 

RampedUp is a registered with the Vermont Secretary of State’s office as a data broker. As such, we “credential” our customers in that use best practices to confirm that our customers are who they say they are, will be using the data collected for the purposes that they say they will be using it for, and will not use the data for nefarious purposes. 

Questions
If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this Site, please contact us at contact@rampedup.io.

Changes to this Policy
This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning material amendments or changes to this Policy. We encourage you to periodically review this page for the latest information on our privacy practices. This Privacy Policy was last updated on the date indicated above.