• Information you provide RPP. RPP collects certain personally identifiable information about you, including information that can identify, relate to, describe, be associated with you, or is reasonably capable of being associated with you (“Personal Information”). Examples of Personal Information that RPP collects include but are not limited to:
• Contact Information. This may include your first and last name, postal address, telephone number, and email address.
• Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.
• Identity Information. If you are a User we may collect Personal Information, such as your date of birth and address, national identification number if applicable, together with the result of basic credit report (if you are seeking funding for a Subject Property), or by our Third-Party Agents (as defined below), as applicable and to the extent permitted by law in your jurisdiction, as well as such information as may be needed to validate your identity.
• Financial Information. To help the our Users set up a payment account and help Users make payments and pay fees to RPP, we may collect financial information, including credit card number, bank routing numbers, tax information, taxpayer identification number, and other payment information, as applicable. We use Financial Information in order to operate the RPP Platform and to ensure that Users pay their respective amount due to RPP for use of the Platform and services provided by RPP. We do this as necessary for our legitimate interests in providing our Platform and services and to fulfill our agreements and varying contracts with Users. To keep your financial data secure, we have a highly reputable third-party that maintains and processes your payment information.
• Promotional Information. Certain offerings of the RPP Platform, such as funding; e-commerce shopping; ebooks and books; educational content; newsletters; surveys; contests; consulting; mentoring; advocacy, and the like (“Offerings”) are optional and so you are not required to enter them or to give us your data in connection with them. Where you do consent to take advantage of RPP Platform Offerings, we will use your data to (as applicable) send you newsletters and other communications that are tailored based on information we have about you, or to operate and manage the survey, contest or similar offering in connection with our legitimate interest in promoting our business and the RPP Platform. To opt-out of receiving marketing communications from us, please see “Your Rights and Choices” detailed below.
• Employment Information. We may also collect employment and education history, transcripts, writing samples, and references as necessary to consider your job application for open positions. RPP vets our prospect personnel to ensure that RPP is delivering superior service to Users.
• Content Information. You also may choose to send RPP Personal Information in an email or chat message containing inquiries about the RPP Platform and we use this Information in order to help us respond to your inquiry. We also collect content within any messages you exchange with other Users through the RPP Platform (such as through our chat functionality).
• We require that you furnish certain information when you register an account with us in order to provide services through the RPP Platform. For example, if you are a User, we collect your first and last name, email address, phone number, and your billing information in order to create and administer your RPP account. We may also collect additional information in order to facilitate your request for one of our Offerings, that information may include your details around your funding request, information regarding the Subject Property, and/or other service you are seeking. If you are a Platform User, we collect your first and last name, email address, and phone number in order to facilitate communications between RPP you and through the RPP Platform. We also collect information about your current employment, career history, schedule of real estate, real estate purchase history, and industry skills, as well as identity information and financial information.
• Third-Party Information. If you registered through a co-branded version of our RPP Platform through one of our partners, or business associates, they may provide us with basic information such as your name, address, email, and purchase history related to your Service needs. We may receive additional information about you, such as demographic data, financial information, or fraud detection information, from Third-Party Agents (as defined below) and combine it with other information that we have about you, to the extent permitted by law, in order to comply with our legal obligations and for the legitimate interest in improving the RPP Platform.

3. Information RPP Collects Automatically

We automatically collect certain information when you use the RPP Platform. The categories of information we automatically collect and have collected, including in the last 12 months, are as follows:

• Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, portions of the RPP Platform that you view and interact with, the time of day you browse, and your referring and exiting pages.
• Device Data, including data about the type of device or browser you use, your device’s operating system, your internet service provider, your device’s
• regional and language settings, and device identifiers such as IP address and Ad Id. When you visit and interact with the RPP Platform, RPP may collect
• certain information automatically through cookies or other technologies, including, but not limited to, the type of computer or mobile device you use,
• your mobile device’s unique device ID, the IP address of your computer or mobile device, your operating system, the type(s) of internet browser(s) you
• use, and information about the way you use the RPP Platform (“Device Information”). We may use Device Information to monitor the geographic
• regions from which Users navigate the RPP Platform, and for security and fraud prevention purposes. Use of any IP-masking technologies or similar technologies (like the TOR network) may render portions of the RPP Platform unavailable and are forbidden on the RPP Platform.
• Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level), and, with your consent, precise location data (such as latitude/longitude data). When you visit the RPP Platform via a native mobile application, we use, with your
• consent when required under applicable law, GPS technology (or other similar technology) to determine your current location in order to determine the city you are located in and display a relevant location map. We will not share your current location obtained in this manner with other Users.
• Cookies and similar technologies are described in our Cookie Policy, which sets out the different categories of cookies and similar technologies
• that the RPP Platform uses and why we use them.
• RPP’s Use of Information

4. RPP’s Use of Information

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:

• To operate and make available the RPP Platform. We use your data to connect you with other Users to enable the posting of, selection for, completion of, and payment for Services, in order to fulfill our contracts with Users;
• For billing and fraud prevention, on the basis of our legitimate interests in ensuring a safe and secure environment in which can meet and conduct business, and in order to comply with our legal obligations;
• To analyze RPP Platform usage as necessary for our legitimate interest in improving the RPP Platform to grow our business;
• To contact you and deliver (via email, SMS, push notifications, or otherwise) transactional information, administrative notices, marketing notifications, offers and communications relevant to your use of the RPP Platform, with your consent when required under applicable law, as necessary for our legitimate interests in proper communication and engagement with our Users, and in promoting our business;
• To provide you with customer support in order to fulfill our contracts with Users;
• For internal market research for our legitimate interest in improving the RPP Platform to grow our business;
• For troubleshooting problems for our legitimate interests in ensuring a safe and secure environment in which Users can meet;
• To assist Users in the resolution of complaints and disputes between them, as necessary for our legitimate interests in facilitating good relations among Users;
• To enforce our Terms of Service and our legitimate interests in ensuring our Agreement is complied with; and
• As otherwise set forth in the Agreement.

Interest-Based Advertising. Ads are a standard part of user experience on the Internet, and RPP believes that targeted advertising enhances this experience. RPP and its affiliated third-parties may use cookies and other technologies to place ads where they believe interested Users will see them. In addition to banner ads, RPP may advertise products, associated companies and events that we think might interest you through the email address and/or phone number you provide. We may incorporate Tracking Technologies (i.e., Facebook Pixels and Google Tags) on the RPP Platform (including our website and emails) as well as into our ads displayed on other websites and services. Some of these Tracking Technologies may track your activities across time and services for purposes of associating the different devices you use and delivering relevant ads and/or other content to you (“Interest-Based Advertising”).

For more information and to understand your choices regarding third-party ads. Advertising and marketing are carried out as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.

Analytics and Market Analysis. RPP may analyze information (“Market Analysis”) as necessary for our legitimate interests in providing an engaging and relevant experience and promoting and growing the RPP Platform.

RPP uses information to offer services to Users who express an interest in these services, through a poll for example, or to Users who can be presumed to have an interest based on results from our Market Analysis. We do this as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.

Cell Phone Numbers. RPP may use your cell phone number to call or send recurring text messages to you, using an auto dialer, and/or prerecorded voice message, and/or AI technologies in order to provide you notifications about our promotions, various services, for marketing purposes (with your consent where required by law), and to administer the RPP Platform. If you would like more information about our policy, or how to opt out, please review the “Your Rights and Choices” section below of our Terms of Service. Although not likely, you may be liable for standard SMS and per-minute charges by your mobile carrier. RPP may also message you via push notifications (with your consent when required under applicable law), which you can opt-out of on your mobile device. Data rates may apply.

Call recordings. Calls to or from RPP or its Third-Party Agents may be monitored and recorded for the purposes of quality control and training. Such calls may contain Personal Information.

5. Information Sharing

RPP will only share the Information we collect about you as described in this Privacy Policy or as described at the time of collection or sharing, including as follows:

Third-Party Agents. We share information, including Identity Information, with entities that process information on our behalf for our business purposes. We will never sell your information to any unassociated business. We contractually prohibit our Third-Party Agents from retaining, using, or disclosing information about you for any purposes other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

To operate the RPP Platform, including processing your transactions, we may share your Personal Information with our agents, representatives, vendors and service providers (“Third-Party Agents”) so they can provide us with support services as follows:

• Email origination;
• Fraud prevention and detection (currently which could be carried out by Third-Party funding providers). Our fraud detection providers also use information relating to you and your use of and activity on the RPP Platform to provide fraud detection services to their other clients;
• Receipt, invoice, or support services;
• Customer relationship management services;
• Data analytics;
• Marketing and advertising;
• Website hosting;
• Communications services;
• Technical support;
• Financial transaction fulfillment (in which we are currently supported by Stripe, who processes your Personal Information in accordance with its own privacy policy) and related chargeback and collection services; and
• To otherwise help us provide the RPP Platform.

Partners. Some RPP content is “powered by” or “presented by” other businesses and various companies. If you connect to the RPP Platform through a co-branded version of our RPP Platform or otherwise participate in one of our partner programs, we may share information about your use of the RPP Platform with that Partner in order to offer the integrated platform and to evaluate the partner program. We may also share your Personal Information with our Partners in order to receive additional information about you, or in order to create offers that may be of interest to you. Please check such Partner’s privacy policy before revealing information about yourself. If you don’t want these Partners to have your Personal Information, you can choose to not participate.

Promotions. When you voluntarily take vacations, enter a giveaway, sweepstakes, contest, or other promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners’ list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except whereas prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice, and/or likeness in advertising or marketing materials. We may occasionally contact you, if you want us to, with information about special events, activities, promotions, association, submission opportunities, and programs. You always have the ability, in your account, to ask RPP not to
contact you with this type of information. Please see, Your Rights and Choices, for more information.

Matched Ads. We use Matched Ads by sharing personal information with another party or incorporating a pixel from another party into our own Sites, and the other party matching common factors between our data and their data or other datasets for advertising purposes. For instance, we may incorporate the Facebook Pixel on our Sites and may share your email address with Facebook as part of our use of Facebook Group/s, Instragram audiences, or other
congregation.

Other Users. RPP facilitates contact between Users and reserves the right to share one User’s contact information (e.g., name, phone number, email, or
postal address) with other Users, or with the recipient User’s legal or other authorized representative, in order to: (1) facilitate or communicate the resolution of an dispute related to or arising from an interaction between two or more Users of the RPP Platform; or (2) facilitate the performance of a Service. This exchange of information is essential to the operation of the RPP Platform.

Legal Obligations. RPP and our Third-Party Agents may disclose your Personal Information or User Generated Content to courts, law enforcement, governmental or public authorities, tax authorities or authorized third parties, if and to the extent required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with RPP’s legal or regulatory obligations;(ii) respond to a court order, warrant or subpoena; (iii) respond to a valid legal request relating to an investigation into alleged criminal or illegal activity; or (iv) respond to or address any other activity that may expose us to legal or regulatory liability. Please be advised that RPP and its associated businesses have a Zero Tolerance Policy with respect to fraud.

In jurisdictions where RPP is, according to applicable law, required to collect or remit information about Users’ permits, licenses, tax, or social security registrations, RPP and our Third-Party Agents may disclose information, including but not limited to, User contact details, identification information, transaction dates and amounts, license and permit status, and tax identification number(s) to applicable governmental authorities. RPP reserves the right to disclose Personal Information from both private and public areas of the RPP Platform in the absence of a court order, warrant, or subpoena, to the extent permitted by applicable law, if we are given reason to believe, in our sole discretion, that someone is causing injury to or interfering with the rights of Users, the general public, or RPP or its partners, parents or affiliates.

It is our policy to provide notice to Users before producing their information in response to law enforcement requests unless (i) we are prohibited or otherwise constrained by law or court order from doing so, (ii) we have reason to believe the User’s account has been compromised such that the notice would go to the wrong person, or notice would otherwise be counterproductive or would create a risk to safety, or (iii) it is an emergency request and prior notice would be impractical (in which case we may provide notice after the fact).

Merger or Acquisition. RPP reserves the right to share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

Platform Public Areas. Your profile on the RPP Platform consists of information about you and your business, and may include information such as photographs, your years in business, skills and expertise, hourly pay rates, feedback/rating information, and other information, including your username (“Profile”). The information in your User Profile may be visible to all Users, the general public, and is visible to Coaches and RPP Management. If you choose to post via the RPP Platform (For You, and/or the Marketplace), the contents of such listing will be viewable to Users on the RPP Platform.

6. Your Rights and Choices

You may opt-out of receiving promotional communications from us, including promotional communications related to the RPP Platform, and request the removal of your Personal Information from our databases, or deactivate your account, by logging on to the Site or App and clicking on the “Account” tab, or by contacting us.

Account Settings. During registration you choose whether to receive marketing correspondence from RPP. This information remains on your Profile where you can, at any point, easily edit it. After logging on, click on the “Account” tab, then select “Notifications” to make your preferred selections.

Push Notifications. You have the option to receive updates and relevant offers via push notifications in your app. These notifications can be configured in
the settings of your mobile device at any time.

Corrections to Profile. You have the right to access, update, and correct inaccuracies in your RPP Profile at any time by logging into the Desktop and clicking on your Profile Pic and clicking the “Manage Account” link from the dropdown menu. There, you can view, update, and correct your Account information.

So that we may protect the integrity of the RPP Platform, there are certain pieces of information that you cannot alter yourself. For example, since children under the age of majority in their jurisdiction of residence are not allowed to register as Users, we need to take reasonable measures to preserve the accuracy of our Users’ ages. You may contact us. If there is a need to make a correction to such data. Please see section below titled Children’s Privacy, for more details.

Promotional Communications. You can opt out of receiving promotional communications from RPP via the Account tab in your Profile. In addition, you can opt out of email marketing by clicking on the unsubscribe link in any message. You can opt out of promotional communications from RPP sent via text message at any time by following the instructions provided in those messages to text the word “STOP” or other like language indicated in the message. Please note that your opt-out is limited to the phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, RPP will continue to send you non-promotional communications, such as those about your account, Services, transactions, servicing, or RPP’s ongoing business relationship with you. If you receive unsolicited promotional communications from a RPP domain, please let us know.

If you are a California Resident, please see the Additional Disclosures for California Residents section below.

7. RPP’s Information Retention Policy

We retain personal data for as long as you are a User in order to meet our contractual obligations to you, and for such longer period as may be in our legitimate interests and to comply with our legal obligations and for various marketing purposes. We may also retain data from which you cannot directly be identified, for example where stored against a randomly-generated identifier so we know the data relates to a single User, but we cannot tell who that User is. We use this kind of data for research purposes and to help us develop and improve our services, and we take appropriate measures to ensure you cannot be re-identified from this data.

8. RPP’s Security of Collected Information

Your RPP account is password-protected so that only you and only authorized RPP staff have access to your account information. In order to maintain this protection, do not give your password to anyone. Also, if you share a computer and your User account, you should sign out of your RPP account and close the browser window before someone else logs on. This will help protect your information entered on public terminals from disclosure to unwanted third-parties.

RPP implements and maintains reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. RPP has staff dedicated to maintaining this Privacy Policy and other privacy initiatives, periodically reviewing security, and making sure that every RPP employee is aware of our security practices. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. However, we are committed to doing our best.

9. Notification of Changes

RPP’s Privacy Policy is periodically reviewed and enhanced as necessary. This Privacy Policy might change as RPP updates and expands the RPP Platform. RPP will endeavor to notify you of any material changes by email. RPP also encourages you to review this Privacy Policy periodically.

10. Children’s Privacy

This service is intended for a general audience and is not directed at those under the age of 18. In certain jurisdictions, this minimum age may be higher. Please check the jurisdiction-specific Provisions below for more information.

We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe that we have collected information from your child in a manner not permitted by law, please let us know by contacting us. We will remove the data.

We do not knowingly collect or “sell” the Personal Information of minors under 18 years old who are California residents under any circumstances.

11. Contacting Us

If you have any questions about this Privacy Policy or the manner in which we or our Third-Party Agents treat your Personal Information, the practices of the Site, your dealings with the RPP Platform, or if you have technical problems, you may contact us.

RPP’s staff will respond to all mail or email from Users with questions about privacy, including the types of Personal Information stored on the RPP databases, and requests to know, delete or rectify such Personal Information.

12. Jurisdiction-Specific Provisions (Reserved)
13. Residents of the United States of America Information of U.S. Users. Our collection, use, and retention of the Personal Information of U.S. Users is in accordance with applicable U.S. laws, as is our determination of what is deemed to be “personal data and/or information.” RPP expressly disclaims any liability that may arise should any other individuals obtain the information you submit to the RPP Platform.

Interest-Based Advertising in the United States. For more information about interest-based ads, or to opt out of having your web-browsing information used for behavioral advertising purposes, please contact us.

RPP’s Security of Collected Information. While RPP will use industry standard and good faith reasonable efforts to ensure the security of all Personal Information, we expressly disclaim any liability for any unauthorized access to or use of our secure servers and/or any and all Personal Information stored therein, and you agree to hold RPP harmless for any damages that may result therefrom.

1. Additional Disclosures for California Residents

These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires business collecting or disclosing Personal Information to provide notice of rights California residents have and can exercise.

California Notice of Collection. We have collected Personal Information corresponding to the following categories enumerated in the CCPA, including within the last 12 months.

• Identifiers, including name, address, email address, account name, Social Security Number, IP address – and an ID number assigned to your account and/or funding request.
• Customer records, phone number, billing address, credit or debit card information, employment or other information.
• Demographic information, such as your age, gender, and financial status (such as to qualify for funding and/or the purchase of a Subject Property. This category includes pieces of Personal Information that also qualify as protected classification characteristics under other pre-existing California or federal laws.
• Analytics and Advertising, including purchases and engagement with the RPP Platform.
• Internet activity, including history of visiting and interacting with our Service, browser type, browsers language and other information collected automatically.
• Geolocation data, including location enabled services such as WiFi and GPS.
• Inferences, including information about your interests and preferences.

For more information on what we collect, including the sources we receive information from, please review Information Collection. We collect and use these categories of personal information for the business purposes described herein, RPP’s Use of Information, including to provide and manage the RPP Platform.

RPP does not sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed herein5, RPP’s Use of Information, as a “sale,” we will comply with applicable law as to such
activity.

RPP may disclose the following categories of information for commercial purposes with our associated businesses and/or companies:

• Financial Information as provided by you;
• Real Property Holdings, or “Schedule of Real Estate” as provided by you;
• Commercial Information;
• Demographic Data;
• Location Data;
• Identifiers;
• Inferences; and
• Internet activity.

We use and partner with different types of entities to assist with our daily operations and manage the RPP Platform. Please review Information Sharing, for more detail about the parties with which we share Personal Information.

Right to Know and Delete. If you are a California resident, you have the right to know certain information about our data practices in the preceding 12 months.
In particular, you have the right to request the following from us:

• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information was collected;
• The categories of Personal Information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the Personal Information was disclosed for a business purpose or
  sold;
• The business or commercial purpose for collecting or selling the Personal Information; and
• The specific pieces of Personal Information we have collected about you

In addition, you have the right to delete the Personal Information we have collected from you. However, this is not an absolute right and RPP may have legal grounds for keeping such data.

To exercise any of these rights, please submit a request with us. 
In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days.

We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

Right to Opt-Out. To the extent RPP sells your Personal Information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your Personal Information by us to third parties at any time. You may request to opt-out by contacting us.

Authorized Agent. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Equal Opportunity Employer.  As an Equal Opportunity Employer, we acknowledge the need for equal opportunity. We simply do not discriminate, and our policy is in alignment with the U.S. Equal Employment Opportunity Commission. Our policy is simple: workplace discrimination will not be tolerated under any circumstances. We do not discriminate against employment candidates or employees based on characteristics such as:

• Race
• Sex
• Age
• Religion
• Disability
• National origin
• Socioeconomic class

Shine the Light. Users who are residents of California may request: a list of the categories of Personal Information disclosed by us to third parties during
the immediately preceding calendar year for those third parties’ own direct marketing purposes, and (ii) a list of the categories of third parties to whom
we disclosed such information. To exercise a request, please contact us at support@realproppro.com or 1017 L Street, NO 485, Sacramento, CA 95814. Requests must include “California Shine the Light Request” in the first line of the description and include your name, street address, city, state, and ZIP code. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. Please note that RPP is not required to respond to requests made by means other than through the provided email address or mail address.

1. Residents and Investors Outside the United States. 

Global Interest-Based Advertising. For more information about interest-based ads, or to opt out of having your web-browsing information used for behavioral advertising purposes, please visit http://youronlinechoices.eu/.

Transfer Of Data. We and our affiliates and Third-Party Agents primarily store data about you, including Personal Information, on servers located and operated within the United States. If you reside or are located outside of the U.S., we may transfer, store, and process your Personal Information (also referred to as personal data under the GDPR) to the U.S. in order to provide and operate the RPP Platform. Whenever your personal data is transferred outside of the EEA, we undertake to ensure an adequate level of protection is afforded to it, either by us, our affiliates, and/or Third-Party Agents, in accordance with applicable data protection law.

Your Rights. You have the following rights under certain circumstances:

• A right of access: you have the right to obtain confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain access to such data and a copy thereof;
• A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement;
• A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. However, this is not an absolute right and RPP may have legal or legitimate grounds for keeping such data;
• A right to restriction of processing:
• in some cases, you have the right to restrict the processing of your personal data;
• A right to data portability: you have the right to receive the personal data concerning you which you have provided to RPP, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from RPP. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
• A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of RPP. RPP may, however, invoke compelling legitimate grounds for continued processing. When your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You can change your marketing preferences at any time as described herein under, Your Rights and Choices.
• You can exercise your rights by contacting us.

1. US & EU Privacy Shield

RPP is aware of the Schrems II judgment which invalidated the Privacy Shield as a matter of EU law. RPP has decided, however, to maintain its certification not to legitimize the transfer of personal data under EU law, but as a matter of US law and good practice.

In compliance with the Privacy Shield Principles, RPP commits to resolve any complaints about our collection or use of your Personal Information. Individuals with inquiries or complaints regarding our handling of your Personal Information under the Privacy Shield should first contact RPP.

As explained in this Privacy Policy, RPP may provide Personal Information to third parties to perform services on our behalf. If we transfer Personal Information received under the Privacy Shield to a third party, the third party’s access, use and disclosure of your Personal Information must also be in compliance with our Privacy Shield obligations, and RPP recognizes potential liability under the Privacy Shield for failure to do so by the third party. RPP is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

1. Residents of Canada.

Transfer Of Data. We and our affiliates and Third-Party Agents primarily store data about you, including Personal Information, on servers located and operated within the United States. If you reside or are located outside of the U.S., we may send and store your Personal Information (also commonly referred to as personal data) to the U.S. in order to provide and operate the RPP Platform. By accepting the terms of this Privacy Policy, you acknowledge the transfer to and processing of your Personal Information on servers located in the U.S.

Custom Audience. We may use services provided by third-party platforms (such as social networking or other websites) to serve targeted advertisements on such platforms to you, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the use of your Personal Information for such purposes, please contact us.

Interest-Based Advertising in Canada. For more information about interest-based ads, or to opt out of having your web-browsing information used for behavioral advertising purposes, please visit https://youradchoices.ca/choices.

To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by third-party advertising companies that participate in the DAAC’s AppChoices tool, please download the version of AppChoices for your device at https://youradchoices.ca/appchoices/.