Effective Date: October 18, 2021
The rights of California residents under this Policy are described in Section 11.
PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR PERSONAL INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT USE OUR SERVICES.
1. SCOPE AND APPLICATION
This Policy applies to persons who use our Services to schedule pickups of waste and recyclable materials by independent haulers identified by Rubicon or (except as excluded elsewhere in this Policy) otherwise interact with Rubicon through the Services, such as by visiting our websites or mobile applications (“Users”). For purposes of this Policy, “personal information” includes your name, postal address, email address, telephone number and any other information that may be used to identify, contact or locate you or is reasonably capable of being associated with you. This Policy does not apply to: (i) information we collect from or about the third party, independent hauling companies that are (or will be) under contract with Rubicon (collectively, “Haulers”); or (ii) information collected by any third party for that third party’s own purposes, including any content that may link to or be accessible through our Services. If you interact with the Services as both a User and a Hauler, the respective Policies apply to your different interactions.
2. UPDATES TO THE POLICY
We may update this Policy from time to time. If we make significant changes in the way we treat your personal information we will provide you with notice through the Services or by some other means, such as email or posting a revised version of the Policy on our website. We encourage you to periodically review the Policy for the latest information on our privacy practices.
3. SOURCES OF PERSONAL INFORMATION
A. INFORMATION YOU PROVIDE TO US
We collect information from you when you directly provide it to us, for example when you register and create or modify your account, request certain services, contact customer support or provide feedback, or otherwise communicate with us.
B. INFORMATION WE AUTOMATICALLY COLLECT
When you use our Services, we may automatically collect information about you.
- Location Information: When you use the Services to schedule a pickup, we may collect precise location data about the pickup location from your mobile device. Depending on your settings on your mobile device, we may collect this information when the app is running in the foreground or background. You may choose to refuse to give Rubicon permission to collect your location information in your mobile device’s settings; however if you choose to do so, your use of the Services may be impaired. We may also derive your approximate location from your IP address. Refusing Rubicon permission to collect your location information will not prevent us from deriving your approximate location from your IP address.
- Transaction Information: We collect transaction details related to your use of our Services, including the type of pickup requested, date and time the pickup was provided, amount charged, weight and substance of the pickup, and other related transaction details.
- Device Information: We may automatically collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, unique device identifier, advertising identifiers, device motion information, and mobile network information.
- Call and SMS Data: We may be required to call or text (SMS) you during your use of the Services. In connection with doing so, we receive call data, including the date and time of the call or SMS message, your phone numbers, and the content of the SMS message.
- Log Information: When you interact with the Services, we automatically collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services, if you are linking to our Services from such third-party site or service.
C. IMPORTANT INFORMATION ABOUT PLATFORM PERMISSIONS
Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Rubicon app wants permission to access certain types of data and will ask you to either consent or not consent to that request. Android devices will notify you of the permissions that the Rubicon app seeks before you first use the app, and your use of the app constitutes your consent.
D. INFORMATION WE COLLECT FROM OTHER SOURCES
We may also receive information from other sources and combine that with information we collect through our Services. For example:
- If you choose to link, create, or log in to your Rubicon account with a payment provider or social media platform, we may receive information about you or your connections from that site or app.
- If you also interact with our Services in another capacity, for instance as a Hauler or user of other apps we provide, we may combine or associate that information with information we have collected from you in your capacity as a User.
4. OUR USE OF YOUR INFORMATION
We may use the information we collect about you to:
- Provide, maintain, and improve our Services
- Personalize and improve the Services, including providing or recommending features, content, and advertisements
- Facilitate pickups between you and a Hauler, including providing estimated times of arrival
- Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of Rubicon and third parties, where permissible and according to local applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards
- Perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends
- Respond to your inquiries and for other customer service purposes
5. SHARING OF INFORMATION
We may share any of the categories of personal information that we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:
- THROUGH OUR SERVICES
We may share your personal information:
- With Haulers to enable them to provide the Services you request. For example, we share your name and pickup location with Haulers. We will not share information with Haulers other than as necessary for them to perform the Services for you
- With other people if directed by you
- With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us
- With the general public if you submit content in a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the general public
- With third parties with whom you choose to let us share information, for example other apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate
- With your employer, if you request the Services on behalf of your employer
- OTHER SHARING
We may share your personal information:
- With Rubicon subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and/or logistics purposes
- With third party service providers such as vendors, consultants, and marketing partners, who need access to such information to carry out work on our behalf
- In an aggregated and/or anonymized form which cannot reasonably be used to identify you
- In response to a request for information by a competent authority if we believe disclosure is in accordance with, or otherwise required by, any applicable law, regulation, or legal process
- In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company
- If we otherwise notify you and you consent to the sharing
6. ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS
8. SOCIAL MEDIA FEATURES
The Services may integrate with certain social media platforms which let you share actions you take on our Services with other apps, sites, or media, and vice versa. Your use of such platforms enables the sharing of information with your friends or the public, depending on your settings with the applicable social media platform. Please refer to the privacy policies of those social media platforms for more information about how they share the data you provide to or share through them.
9. ACCOUNT INFORMATION
You may update or correct information about yourself at any time by logging into your in-app account. If you wish to cancel your account, please delete our app and email us at email@example.com. In some cases, we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law.
10. PROMOTIONAL COMMUNICATIONS
You may opt out of receiving promotional messages from us by following the instructions in those messages. Please allow us a reasonable period of time in order to satisfy your request, as some promotions may already be in process. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.
11. YOUR CALIFORNIA PRIVACY RIGHTS
This section provides the information required to be disclosed, and the rights California residents have, under the California Consumer Privacy Act (CCPA). The CCPA currently exempts personal information reflecting a business-to-business communication (“B2B Personal Information”) from certain of the law’s requirements, and also currently exempts personal information collected and used about a natural person acting as a business’s employee or contractor (“Personnel Information”). The rights described below may not apply to B2B Personal Information or Personnel Information.
The information that we have collected and disclosed (as described above) in the past 12 months is along the following categories for the purposes of the CCPA:
|Category||Collected?||Disclosed for a business purpose?|
|A. Identifiers, e.g., name and email address.||Yes||Yes|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), e.g., address, telephone number and employer.||Yes||Yes|
|C. Protected classification characteristics under California or federal law.||No||No|
|D. Commercial information.||Yes||Yes|
|E. Biometric information.||No||No|
|F. Internet or other similar network activity.||Yes||Yes|
|G. Geolocation data.||Yes||Yes|
|H. Sensory data.||No||No|
|I. Professional or employment-related information||No||No|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||No||No|
|K. Inferences drawn from other personal information.||No||No|
We do not sell your personal information, and we do not share your personally identifiable information with third parties for the third parties’ direct marketing purposes unless you provide us with consent to do so.
Under CCPA, California residents have the following rights with respect to their personal information:
- The right to receive information about the categories of personal information we have collected about you, the categories of sources we have received it from, the business or commercial purpose for collecting or selling it, the categories of third parties with whom we have shared personal information, and the specific pieces of information we have collected about you.
- The right to obligate us to delete the personal information we have collected about you excluding that collected in a limited set of circumstances, such as personal information processed to complete a transaction and retention of personal information necessary for legal compliance.
- The right to opt out of the sale of your personal information. Please note, however, that we do not sell your personal information.
- The right not to be discriminated against for exercising any of the preceding rights.
You may exercise the rights above by submitting a request to firstname.lastname@example.org or by telephone at (844) 479-1507. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. We may also need to collect additional information about your previous interactions with Rubicon to verify and fulfill your request. Please allow up to forty-five (45) days for the completion of your request.
You may authorize an agent to make a CCPA request on your behalf. We will seek to verify your identity and your agent’s authority when we receive an individual rights request made on your behalf to ensure the security of your personal information, and may need to collect additional personal information to do so, e.g., by requesting documents showing your agent’s authority (such as powers of attorney).
We will not discriminate against you for exercising any of these data rights. To the greatest extent possible, we will provide you with the same quality of service at the same price after exercising these rights.
12. Other Data Protection Rights
Depending on the jurisdiction in which you reside, and subject to applicable data protection laws, you may have the following data protection rights: to access; correct; update; port; delete; restrict; or object to our processing of your personal information. We respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. Please send such requests to email@example.com. We may ask you to verify your identity in order to help us respond efficiently to your request.
13. Using the Services from Outside of the United States
If you are using the Services from outside of the United States of America, please be aware that your information may be transferred to, stored or processed in the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. For example, we and our customers and partners strive to take commercially reasonably efforts to put in place appropriate safeguards or identify an applicable derogation required for affecting the data transfer.
14. Residents of the European Economic Area (EEA), United Kingdom (UK), and Switzerland
This portion of our Policy applies to Users in the EEA, Switzerland and the United Kingdom only and applies to the extent of any inconsistency with the information above. All terms not otherwise defined in this section shall have the meanings as defined under applicable data protection laws.
Consent. We will make it clear if we rely on your consent to process your personal data and, where we rely on consent as a basis for processing personal data, you are free to withdraw your consent at any time. If you wish to do so, please contact us at firstname.lastname@example.org.
Legitimate Interest. Another reason we might use your personal data is because we have—or a third party has—a legitimate interest in doing so. We do so when responding to your inquiries about our products and services; to provide services and technical support to you; and to enable internal administrative processes, such as account administration.
Retention Period. When we no longer need to process your personal data for the purposes described in this Policy, we will delete your personal data from our systems. We therefore generally retain information when we have an ongoing legitimate business need for the information and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Providing Your Data. One reason we might use your personal data is because you’ve inquired into entering into a contract with us or your organization has entered into a contract with us and we need to provide services under that contract. We may not be able to fulfill that contract if you choose not to provide us with your personal data.
Purpose of Processing. When we process your personal data, we determine the purpose of the processing and act as a controller. We will primarily process personal data to offer our products services, process payments, and to provide prospective customers with information about our products, in addition to other purposes set out in this Policy.
Automated Decision Making. We do not engage in any automated decision making as a part of our Services.
Rectification. We want our records to be as accurate as possible, so please advise us of any errors and we will make corrections accordingly. A difference of opinion or view does not necessarily mean that personal data is inaccurate. If you have a difference of opinion, we will do our best to add that opinion to our records.
Erasure and your “Right to be Forgotten”. Please contact us at email@example.com if you want us to delete your personal data. We will do our best to honor your request, but we may have an obligation to keep records for audit and legal purposes. We may also be able to “Restrict Processing” or delete specific information or a document, which we will do without undue delay, for example, where it has been sent to us in error.
Object to Processing. In certain circumstances, you may have the right to object to our use of your personal data, such as if we are using your personal data for direct marketing or for our or a third party’s legitimate interests. Please contact us at firstname.lastname@example.org if you would like us to do so.
Right to Restrict Processing. Under some circumstances, you may request that we limit how we use your data or “Restrict Processing.” Simply a difference of opinion or view does not necessarily justify a restriction, but we will always consider your opinion. We will always inform you before we lift any restriction.
Access Data. You may, subject to certain exceptions, receive a copy of your personal data from us. If you would like to do so, please contact us at email@example.com and we will advise you of the next steps as soon as possible.
Data Portability. At your request, we are happy to provide your personal data in a machine-readable or “portable” format so you can move it or store it wherever you want, subject to certain limitations. We can also send it to another controller where technically feasible. If you would like to do so, please contact us at firstname.lastname@example.org and we will advise you of the next steps.
Right to Complain. If you have a complaint about how Rubicon uses your personal data, we hope that in the first instance you will contact us and we will promptly address your concern. However, you can always file a complaint with the supervisory authority in your jurisdiction. For more information, please contact your local data protection authority (contact details for data protection authorities in the EEA are available at https://edpb.europa.eu/about-edpb/board/members_en; and contact details for the data protection authority in the UK are available at https://ico.org.uk/).
Charges/Fees. We do not charge you a fee for exercising any of your rights described above.
15. Linked Websites
16. CHILDREN’S PRIVACY
Users must be at least 18 years of age, or the age of legal majority in their jurisdiction (if different than 18) to download and use our Services. We do not collect any information regarding children under the age of 16. If we learn that we have collected or received personal information from a child under the age of 16, we will delete that information. If you believe that we might have any information from or about a child under 16, please contact us using the contact information at the end of this Policy.
17. CONTACT US
If you or your agent have any questions about this Policy, please contact us at (844) 479-1507.