Terms of Service +
Privacy Policy

1. PURPOSE

Rocky Mountain College of Art + Design (RMCAD), is committed to making your experience online satisfying and safe. Your privacy on the Internet is of utmost importance to us.

Notice at Collection. At or before the time of collection, California residents may have a right to receive notice of our practices, including the categories of Personal Information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared and how to opt-out of such uses, and how long such information is retained. You can find those details in this policy.

We provide this Privacy Policy to inform you of our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and your rights with respect to such information.

2. SCOPE

This Privacy Policy applies to personal information that we process in the course of our business (“Personal Information”); including, but not limited to websites owned and operated by RMCAD such as RMCAD.edu and its subdomains (collectively, the “Sites”), our applications for mobile devices (“Mobile Apps”), and our various offline information collection methods, including without limitation the completion of lead forms sourced by third-party data aggregators (collectively, the “Services”).

3. TYPES OF INFORMATION WE COLLECT AND HOW WE USE IT

3.1 TYPES OF PERSONAL INFORMATION WE COLLECT

The categories of Personal Information we collect depends on the nature of the relationship you have with RMCAD, e.g., prospective or enrolled student, graduates, and site visitors or campus guests (collectively, “you,” “your,” or “Individuals”), and the requirements of applicable law.

• You may provide Personal Information directly to RMCAD through interacting with the Services, participating in surveys, during events, contests, and by requesting Services or information from us.
• We may collect information using various information collection methods including without limitation the completion of lead forms sourced by third-party data aggregators.

In particular, we may collect the following categories of Personal Information:

• Information You Provide Directly to Us. When you use the Services, we may ask you to provide us with Personal Information (such as your first and last name, email address, phone number, country, zip code, and learning preferences). These voluntary submissions include making a request that RMCAD send you additional information about its programs, via email, regular mail, telephone, SMS, and/or other messaging apps.

If you apply to RMCAD degree programs online, you will also be required to provide your gender, date of birth, social security number, physical address, ethnicity, education background, veteran status, citizenship, languages spoken, payment information (for processing deposits and fees) and other information as necessary to process your application and/or determine your eligibility for financial aid, military benefits, institutional aid and/or scholarships.

• Information From Enrolled Students. If you enroll in RMCAD, we will collect and track information about your academic progress, such as scholarship information, classes and grades, attendance, dates of accessing the online platform, training status, last dates of attendance, credits earned, and financial information of students and their parents (e.g., FAFSA data) and other information related to your enrollment.
• Information From Alumni. We may collect Personal Information from or about alumni including, but not limited to, name, email address, phone number, educational information, date of birth, employment information, and other information.
• Communications with Us. We may collect Personal Information from you such as your email address, phone number or mailing address when you choose to request information about us and our programs, request to receive customer or technical support, or otherwise communicate with us, including through the on-line chat live function on our Sites. We retain call and email notes and collect other information that you provide when communicating with us.
• Surveys. From time to time, we may contact you to participate in online surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities.
• Social Media Content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections unless otherwise required by applicable law.
• Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information about winners.
• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, posts, commenting functionalities, forums, blogs, and social media pages). For example, if you use our Services to send direct messages to another individual, we may access the contents of those direct messages. Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
• Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web or mobile application analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, MIME type, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, domain name, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, your preferences, and other actions taken through your use of the Services.
• Information From Other Sources. We may receive information about you from other sources, including through third-party services and organizations including consumer data brokers to supplement information provided by you. In addition, if you access our Services through a third-party application, we may collect personal information about you from that third-party application that you have made available via your privacy settings.
• Analytics. We may use Google Analytics and other service providers to collect information regarding visitor behavior and demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to www.tools.google.com/dlpage/gaoptout.

3.2 HOW WE USE YOUR PERSONAL INFORMATION

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

• To Provide Products, Services, or Information Requested. RMCAD may use information about you to administer and provide the Sites and Mobile Apps to you, and to administer your inquiries and fulfill requests for products, Services, or information, including information about potential or future Services, including to:
  • Generally manage Individual information and Accounts;
  • Respond to questions, comments, and other requests;
  • Provide access to certain areas, functionalities, and features of RMCAD’s Services;
  • Create an account;
  • Purchase merchandise;
  • Contact you to answer requests for customer support or technical support; and
  • Allow you to register for events.
• Administrative Purposes. RMCAD may use Personal Information about you for its administrative purposes, including to:
  • Measure interest in RMCAD’s Services;
  • Develop new products and Services;
  • Ensure internal quality control;
  • Verify Individual identity;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Communicate about Individual Accounts and activities on RMCAD’s Services and systems, and, in RMCAD’s discretion, changes to any RMCAD policy;
  • Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
  • Process payment for products or services purchased;
  • Share Personal Information with third parties as needed to provide the Services;
  • Process applications and transactions;
  • Verify eligibility for financial aid, military benefits, institutional aid and/or scholarships.
  • Undertaking research for technological development and demonstration; and
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
• Marketing RMCAD Products and Services. RMCAD may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. RMCAD may provide you with these materials by phone, SMS, messaging apps, postal mail, facsimile, and email, as permitted by applicable law. Such uses include:
  • To tailor content, advertisements, and offers;
  • To notify you about offers, products, and services that may be of interest to you;
  • To provide Services to you and our sponsors;
  • For other purposes disclosed at the time that Individuals provide Personal Information; or Otherwise with your consent.

You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described below.

• Direct Mail, Email, and Outbound Marketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, messages via messaging apps, newsletters, or mailings from us with information on RMCAD’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer you the option to decline these communications at no cost to by following the instructions below.
• SMS and Telemarketing. Individuals who provide us with their telephone number or whose telephone number we obtain from Third Parties may receive SMS text messages or phone calls with information on RMCAD’s products and services or upcoming special offers/events we believe may be of interest. We offer you the option to decline these communications at no cost by following the instructions below.
• Services via Mobile Devices. From time to time, RMCAD may provide Services that are specifically designed to be compatible and used on mobile devices. RMCAD will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of RMCAD’s Services may require that users log in with an Account. In such cases, information about use of mobile versions of the Services may be associated with Accounts. In addition, RMCAD may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to RMCAD to enable Individuals to access Accounts and to enable RMCAD to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. RMCAD may use personal or non-identifiable information transmitted to RMCAD to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices RMCAD provides.
• De-Identified and Aggregated Information Use. RMCAD may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access RMCAD’s Services, or other analyses we create. We and our service providers use de-identified and aggregated information for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services, research, internal analysis, analytics, and any other legally permissible purposes.
• Other Uses. RMCAD may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information, or with your consent.

3.3 COOKIES, PIXEL TAGS/WEB BEACONS ANALYTICS INFORMATION, AND INTERNET-BASED ADVERTISING

We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

• Pixel Tags. RMCAD works with multiple marketing partners to display retargeted ads to users of our Sites, on our behalf, across the Internet. They collect information about your visits to our Sites and your interaction with our products and Services. We collect information through the use of pixel tags, “clear GIFs,” and javascript-based tracking means, which are industry standard technologies that most major websites use. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
• Cookies. We may place a text file called a “cookie” in the browser files of your computer. A cookie cannot read data off your hard disk or read cookie files created by other sites. RMCAD uses cookies to track user traffic patterns (as described above) and for other purposes set forth in this Privacy Policy. You can refuse cookies by turning them off in your browser. You do not need to have cookies turned on to use the Sites. Nevertheless, there may be certain portions of the Sites that can only be used if cookies are turned on. For example, cookies are necessary for a user to access portions of the Sites that require a valid user account.
• Social Media Widgets. Our Sites include social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Sites. Your interactions with these features are governed by the privacy policy of the company providing it.

Our uses of such Technologies fall into the following general categories:

• Operationally Necessary. We may use Technologies that are necessary to the operation of our Services. This includes technologies that allow you access to Services; that are required to identify irregular Site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
• Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Site content or Mobile Apps;
• Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Sites;
• Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on third-party sites. This includes using Technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
  If you would like to opt out of the Technologies we employ on our Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.

3.4 LINKS TO OTHER SITES

The Sites may include links to other websites maintained or controlled by third parties unrelated to RMCAD. If you click on such a link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. We advise you to review the individual privacy policies of each external site that you use. Visiting these other websites or applications is at your own risk.

RMCAD’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

4. THIRD-PARTY PAYMENT PROCESSING

We may sell merchandise through our Services. When you make purchases through the Services, we process your payments through a third-party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”) and Social Networking Sites (“SNS”) such as Facebook. The third-party application may collect certain financial information from you to process a payment on behalf of RMCAD, including your name, email address, address and other billing information.

5. HOW WE SHARE YOUR PERSONAL INFORMATION

5.1 INFORMATION WE SHARE WITH THIRD PARTIES

We may share your information as described in this Privacy Policy (e.g., with our third-party service providers; to comply with legal obligations; to protect and defend our rights and property or with your permission).

• Service Providers. We may engage certain third parties to facilitate the Services on our behalf, to perform Site and Mobile Apps-related services (e.g., without limitation, hosting and maintenance services, customer relationship services, web and mobile analytics, payment processing and database storage and management services). RMCAD also shares information about prospective students with Third Parties that RMCAD uses to evaluate potential applicants.
• Third Parties You Share or Interact With. The Services may allow you to allow you to share personal information or interact with other third parties.
• Internet Based Advertising and Third-Party Marketing. We may share aggregated information that includes your Personal Information, non-identifying information, and usage tracking information with third parties for industry analysis and demographic profiling and to deliver targeted advertising about other products and services. Through our Services, RMCAD may allow third party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information (such as demographic information and past purchase history) as well as selected Personal Information we have collected with Third Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-RMCAD related websites within their networks. This practice is commonly referred to as “targeted advertising”, “personalized advertising”, “interest-based advertising” or “online behavioral advertising.” Under some privacy laws, these activities may be considered a “sale” of your Personal Information. We may allow access to other data collected by the Sites to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with third party advertising partners, you may opt out of such sharing at no cost by following the instructions below.
• Compliance with Laws and Law Enforcement. RMCAD cooperates with government and law enforcement officials and private parties to enforce and to comply with applicable law or valid legal process. RMCAD may disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of RMCAD or a Third Party, to protect the safety of the public or any person or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity, or if we in good faith, believe that disclosure is otherwise necessary or advisable.
• Business Transfers. RMCAD may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or similar corporate transaction, or in the event of bankruptcy.

5.2 INTERNATIONAL DATA TRANSFERS

All Personal Information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

If we transfer Personal Information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your Personal Information, please contact us as set forth below.

6. YOUR CHOICES

You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to RMCAD’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting us as set forth below.

6.1 EMAIL, SMS, AND MESSAGING APP COMMUNICATIONS

You may opt out of email communications from RMCAD at any time by clicking on the “unsubscribe” link found at the bottom of every email. Requests are processed as they are received; however, some email communications are planned in advance and may continue to be sent for a few days following your unsubscribe request. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding RMCAD and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to this Privacy Policy).

Where you have consented to RMCAD’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting:

RMCAD Marketing
Privacy Policy Information
1600 Pierce Street
Lakewood, CO 80226
[email protected]

6.2 MOBILE DEVICES

RMCAD may occasionally send you push notifications through our Mobile Apps with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. RMCAD may also collect location-based information if you use our Mobile Apps. You may opt out of this collection by changing the settings on your mobile device.

6.3 COOKIES AND INTERNET-BASED ADVERTISING

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from organizations that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or www.youronlinechoices.eu and www.aboutads.info/choices.

To be clear, whether you are using our opt out or an online industry opt out, these cookie-based opt outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your computer browser, that opt out will not be effective on your mobile device. You must separately opt out on each device.

6.4 DO NOT TRACK

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

7. YOUR PRIVACY RIGHTS

In accordance with applicable law, you may have to the following rights:

Confirm Whether We Are Processing Your Personal Information (the right to know).

• Access to/Portability of Personal Information. You can receive a copy of the Personal Information we process about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Information transferred to another party.
• Correction. You can request correction of your Personal Information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Information or we may refer you to the controller of your Personal Information who is able to make the correction.
• Deletion. You can request we delete Personal Information we collect or maintain about you, subject to certain exceptions prescribed by law.
• Restrict or Object to Processing. You can request restriction or object to the processing of your Personal Information.
• Opt-Out of Certain Processing Activities including, as applicable, if we process your Personal Information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your Personal Information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws).
• Withdraw your Consent to our processing of your Personal Information.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

If your Personal Information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your Personal Information violates applicable law.

• EEA Data Protection Authorities (DPAs)
• Swiss Federal Data Protection and Information Commissioner (FDPIC)
• UK Information Commissioner’s Office (ICO)

California Shine the Light Law. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. If you would like to exercise any of these rights, please contact us, as set forth below.

8. CONTACT US

If you have any questions or concerns about our processing activities, or if you want to exercise your rights, you may contact us as set forth herein, by sending an email to [email protected], or mailing us at:

RMCAD Marketing
Privacy Policy Information
1600 Pierce Street
Lakewood, CO 80226

Please include your full name, email address associated with your account, and a detailed description of your data request. Such requests will be processed in line with applicable laws. To protect your privacy, RMCAD will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. To designate an authorized agent, please provide us with written authorization signed by you and your designated agent.

9. DATA RETENTION

RMCAD retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

To determine the appropriate retention period for Personal Information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, certain risk factors, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means.

10. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents supplements our Privacy Policy and only applies to our processing of Personal Information of California residents that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”).

10.1 CATEGORIES OF INFORMATION WE COLLECT AND THIRD PARTIES WE DISCLOSE INFORMATION TO

The CCPA provides California residents with the right to know what categories of Personal Information we have collected about them, whether we disclosed that Personal Information for a business purpose (e.g., to a service provider), whether we “sold” that Personal Information, and whether RMCAD “shared” that Personal Information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:

Category of Personal Information Collected by RMCAD	Category of Third Parties to Whom Personal Information is Disclosed to for a Business Purpose	Category of Third Parties Personal Information to Whom Personal Information is Sold and/or Shared
Identifiers	Service providers Third parties you share or interact with	Advertising partners
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Service providers Third parties you share or interact with	Advertising partners
Protected classification characteristics under California or federal law	Service providers	N/A
Commercial information	Service providers	Advertising partners
Biometric information	N/A	N/A
Internet or other electronic network activity	Service providers	Advertising partners
Geolocation data	N/A	N/A
Sensory data	N/A	N/A
Professional or employment-related information	Service providers Third parties you share or interact with	N/A
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99))	Service providers	N/A
Inferences drawn from other personal information to create a profile about a consumer	Service providers	Advertising partners
Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number	Service providers	N/A
Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account	Service providers	N/A
Personal information that reveals a consumer’s precise geolocation	N/A	N/A
Personal information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership	Service providers	N/A
Personal information that reveals the contents of a consumer’s mail, email, and text messages unless RMCAD is the intended recipient of the communication	N/A	N/A
Personal information that reveals consumer’s genetic data	N/A	N/A
Biometric information that is processed for the purpose of uniquely identifying a consumer	N/A	N/A
Personal information collected and analyzed concerning a consumer’s health	N/A	N/A
Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation	N/A	N/A

The categories of sources from which we collect Personal Information and our business and commercial purposes for using and disclosing personal information are set forth in “Types of Information We Collect and How We Use It,” and “How We Share Your Personal Information” sections above, respectively. We will retain personal information in accordance with the time periods set forth in the “Data Retention” section above.

We “sell” and “share” your personal information to provide you with “cross-context behavioral advertising” about RMCAD’s products and services.

10.2 ADDITIONAL PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

Opting Out of “Sales” of Personal Information and/or “Sharing” for Cross-Context Behavioral Advertising under the CCPA. California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.” California residents may exercise these rights by emailing us at [email protected].

Disclosure Regarding Individuals Under the Age of 16. RMCAD does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. RMCAD does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”

Disclosure Regarding Sensitive Personal Information. RMCAD only uses and discloses sensitive personal information for the following purposes:

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at RMCAD and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by RMCAD, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by RMCAD.
• For purposes that do not infer characteristics about individuals.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

11. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in “Contact Us” above.

12. OUR POLICY TOWARD CHILDREN

The Services are not directed to children under 16, or other age as required by local law outside of the United States. We do not knowingly collect Personal Information from children, or other age as required by local law. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [email protected]. If we become aware that a child under the age of 16 (or other age as required by local law outside of the United States) has provided us with Personal Information in violation of applicable law, we will promptly take steps to delete such information from our files, unless we have a legal obligation to keep it, and terminate the child’s account.

13. CHANGES TO PRIVACY POLICY

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.