Rich Data Solution Privacy Notice

LAST UPDATED: August 28, 2023

Rich Data Solution, LLC, its subsidiaries and affiliates (collectively “Rich Data Solution” or “we”) recognizes the importance of protecting the privacy of information provided to us by those who use our products and services. Our goal is to provide you with an experience that delivers the information, resources and services that are the most useful to you. In order to achieve this goal, we may collect information from you.

This privacy notice explains how we collect, use and disclose information about you when you use our websites, mobile apps, and other online products and services that link to this Notice; subscribe to our publications and newsletters; participate in learning or research activities; attend our events; purchase other products or services from us (collectively, the “Services”) or when you otherwise interact with us or receive a communication from us related to the Services. For certain Services we may provide you with additional privacy information that supplements this Notice.

Please be sure to read this Privacy Notice before using any Service offered by Rich Data Solution or its subsidiaries and affiliates or submitting information to us. This Privacy Notice is current as of the date written above. If we change our privacy practices, we will also update this Privacy Notice. Users should review this notice periodically to monitor any changes. Your continued use of our Services constitutes your acceptance of this Privacy Notice, as updated from time to time.

Please note, this notice includes sections with additional information for users in specific jurisdictions. We will only process your personal data in accordance with applicable data protection and privacy laws. Importantly, we note that we are a “controller” for those Services where we make decisions on how personal information is used in connection with our Services, and we are a “processor” for those services where we only use personal information as allowed by our customers. For the purposes of UK and EU data protection legislation, when acting as a “controller”, the data controller is Rich Data Solution, LLC, a Delaware limited liability company, 2740 SOUTH RD, POUGHKEEPSIE, NY 12601. You understand that your personal data, including any data you provide, is processed by Rich Data Solution in the United States, which may have different data protection standards if you reside in another country.

What information does Rich Data Solution collect?

Information You Provide to Us. We collect the information you provide to us directly when you use the Services, including when you:

• Subscribe to a publication or a newsletter; register for or attend a webinar or an event; or purchase a product (such as a research report or continuing education program)
• Participate in a quiz, poll, contest, promotion, focus group or survey
• Submit Content to the Services or Interact with Content
• Contact Us or Provide Feedback

Automatically Collected Information. We (and service providers on our behalf) automatically collect certain information about your use of the Services, including any devices used to access the Services. For example, we may collect:

• Device information such as hardware model, IP address, device identifiers, operating system, browser type and settings (like language and available font settings) and settings of the device you use to access the Services.
• Usage information such as the Services you use, the time and duration of your use, and other information about your interaction with content, such as the articles you read, where you click on our site, customer service interactions, cursor movements, and certain screen interactions and images (please note we do not capture personal information that you type into form fields (e.g., name or email address) before you submit such information), and how you interact with our emails.
• Location information such as general location derived from your computer’s IP address, your mobile device’s GPS signal, or information about nearby WiFi access points and cell towers that may be transmitted when you use certain Services.

We and our service providers may use cookies, web beacons, and other tracking technologies to collect such information. See our Cookie Notice for more information about these technologies.

When is personally identifiable information collected?

Rich Data Solution collects information by which someone could identify you as a specific, identifiable individual (we refer to this type of information in this Privacy Notice collectively as “personal data”) that you choose to provide us when you subscribe to our publications, sign up for e-newsletters, enter a contest, participate in surveys, login into our Websites using a third party login system (including, but not limited to, Facebook Connect, LinkedIn, X (formerly known as Twitter), etc.), register for a Website, webinar, continuing education course, conference, trade show, or otherwise communicate with us. When you provide this information to us, you are no longer anonymous.

We also collect, use, and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data since it does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. If we combine non-personal data with personal data, we will treat the combined information as personal data under this Privacy Notice.

Categories of Personal Data Collected.

If You Fail to Provide Personal Data Where Such Data is Required to Provide Services to You

Where we need to collect personal data under the terms of a contract we have with you, or a prospective contract, and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). If so, we may have to cancel the service you have with us (or have requested from us), and you accept that as a condition of service.

We will tell you at the time we collect information whether the information requested is necessary for you to participate in a particular feature.

Personal Data Retention

We will retain your personal data and any information collected from your use of our Services for as long as you are a Customer or Subscriber or otherwise maintain a user account on our Websites and for a reasonable time thereafter.

How do we use and disclose the information we collect?

The information we collect is used to respond to your specific requests, to send you periodic information and special offers from Rich Data Solution and our Business Partners (described below) who sponsor one or more of our products or services, to provide you with updates on Rich Data Solution offerings and features, to provide you with product information relevant to you from manufacturers or service providers in our database, and to provide our Business Partners with information about our users.

We may use your contact information to send notices for subscription renewal or provide you with information about products or services you have ordered with us. We may also use your contact information to send you e-newsletters or other promotional e-mails that contain targeted, relevant content that may be useful to you or your business. All promotional e-mails you receive from us will include an option to opt out of similar e-mail communications in the future.

We use the information we collect, including personal data and Website usage data:

• to enable you to use our Websites, to create an account or profile, to process information you provide via our Websites (including verifying that your email address is active and valid) and to process your transactions;
• to provide related customer service and care, including responding to your questions, complaints, or comments and sending surveys and processing survey responses;
• to provide you with information, products, or services that you have requested;
• to receive and process job applications for jobs with us or freelance engagements with us;
• for internal business purposes, such as to improve our Websites and services;
• to administer and process contests, sweepstakes, and promotions;
• to contact you with administrative communications and, in our discretion, changes to our Privacy Notice, Terms and Conditions of Use, or any of our other policies;
• to comply with regulatory and legal obligations; and
• to provide you with information, products, or services that we believe in good faith will interest you, including special opportunities from us and our third-party Business Partners;
• to tailor content, recommendations, and advertisements we and third parties display to you, both on the Websites and elsewhere online;
• for such purposes as disclosed at the time you provide your information, with your consent, and as further described in this Privacy Notice.

You can opt-out of Rich Data Solution processing your personal information for targeting advertising across unrelated websites (known as ‘cross-contextual behavioral advertising’) under applicable state law by: (1) submitting this OPT-OUT FORM, (2) email dpo@richdatasolution.co, or (3) by mail to Rich Data Solution, Attention: Data Privacy Officer, 2740 SOUTH RD, POUGHKEEPSIE, NY 12601. We do not sell or share personal information with unrelated third parties for them to use in cross-contextual behavioral advertising.

We may disclose your information to:

• Affiliates within our family of affiliated companies.
• Business Partners to provide you with Services that you participate in or request, such as sponsors of certain content or events, co-sponsors of a promotion or activity that runs in connection with our Services. We are not responsible for the privacy practices of these entities.
• Service Providers that provide services on our behalf, such as hosting vendors, analytics or advertising and marketing service providers, list managers, and payment processors.
• Other Parties When Required by Law or as necessary to protect our users and Services including as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, our company, employees or agents, customers or users, or to comply with applicable law or legal process, including responding to requests from public and government authorities.
• Social Media Services, if you log into the Services with a social media service or if you connect a social media account with the Services. In that case, we may disclose certain of your personal information to that social media service depending on your settings. The social media service’s privacy notice then applies to their practices regarding your information. We are not responsible for the privacy practices of these entities.
• Third Parties that Provide Advertising, Content, or Other Functionality. Third parties may collect or receive certain information about you and/or your use of the Services to provide ads, content, or functionality, or to measure and analyze ad and content performance on our Services.
• Other Parties in Connection with a Corporate Transaction. We may disclose information we have about you in the event that we sell or transfer all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition, or in connection with a bankruptcy reorganization, or in contemplation of or due diligence related to such a corporate transaction.
• Otherwise With Your Consent or At Your Direction. We may also disclose information about you with third parties whenever you consent to or direct such sharing.

We may disclose aggregated information about users that does not identify any individual, without restriction.

How does Rich Data Solution secure and store your information?

We use reasonable precautions, including appropriate technical, administrative, and physical procedures, to try to protect collected Personal data from loss, misuse, or unauthorized disclosure or alteration.

Our Site uses Transport Layer Security (TLS) to protect personal data. By using a browser that supports security functions, when you access to our Websites and enter Personal data, including your name and e-mail address, this information is transferred to our server and the information is automatically encrypted when transmitted and received by servers. Therefore, if the transmitted data is intercepted by a third party, there is no need to worry about the content being stolen.

If you use a browser that does not support TLS, you may not be able to access our Website or input information.

Due to the design of the Internet and other factors outside our control, we cannot guarantee that communications between you and our servers will be free from unauthorized access by third parties.

Any information you provide may be stored and maintained in an Rich Data Solution database, either housed at Rich Data Solution or with a third party service provider. In the case of a sale, change of ownership or merger involving Rich Data Solution or any parent, subsidiary or affiliated company, your information may be transferred to a third party.

In some cases, you may use passwords to access our Services and customize your information, preferences and experience with our Services. We recommend that you do not share your password(s) with anyone, and notify us promptly if you believe your password security has been breached. Rich Data Solution will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. Also, if you are using a computer that others have access to, such as one in a computer lab, Internet cafe or public library, always remember to log out and close your browser window when leaving any of our Websites.

In addition, any personally identifiable information or sensitive data that you choose to disclose through any discussion boards or other public online forums hosted on the Website, such information may be collected and used by others. We recommend caution when giving out personal information to others in these public online forums. When you provide information on these forums, you do so at your own risk. Rich Data Solution does not take any steps to protect the privacy of information you volunteer about yourself in public forums or other publicly accessible sections of our Websites. The information you share may be viewed by any other user of the Website.

Third Party Content and Links

Our Services may embed content from, or link to, third-party websites and services, including social media platforms, that are outside of our control. We are not responsible for their practices and this Privacy Notice does not govern those third parties’ content, services, or use of your information.

Many of our Websites contain links to Websites owned and operated by unaffiliated third parties. These links are provided as a service to you, and do not constitute Rich Data Solution’s endorsement or support of those third parties or their Websites. Each third party Website has its own information collection and use practices, and we advise you to review their policies.

Rich Data Solution is not responsible or liable for third party privacy practices or the content of third party sites. We are not responsible or liable for any breach of security or for the actions of these parties.

What options do you have about how Rich Data Solution uses or shares your information?

We strive to provide you with choices regarding the personal data you provide us. To exercise control over your information, we have provided you with the following mechanisms:

If you no longer wish for us to share your mailing address or other contact information with our sponsors or other third parties, you may adjust your account preferences or you can send us an e-mail at dpo@richdatasolution.co. For us to be able to locate your record, your e-mail must include your name, mailing address, e-mail address, and must identify the Rich Data Solution product, event, or service for which you are registered. We will strive to process your request within 10 business days, and thereafter we will no longer share your contact information with third parties. Please note that we will not be able to stop third parties from sending you information about their products or services if your information was shared with them before we received your request.

Regarding e-mail specifically, you have the opportunity to elect to stop receiving advertising messages from Rich Data Solution about our products or services each time you receive such a communication from us. To unsubscribe from such advertising e-mail messages, please follow the directions included in that e-mail message. We will strive to process your request within 10 business days. Please note that during that time, you may continue to receive e-mail messages from Rich Data Solution about its products or services or those of our affiliates or customers.

If you receive broadcast e-mail messages that we may send about third party manufacturers or service providers in whose products or services we believe you may be interested and no longer wish to receive such messages, you can do so by following the directions included in the e-mail message you receive. If you have further questions regarding your options with respect to your account information, please contact us at the e-mail or mailing address included at the beginning of this Privacy Notice.

Additionally, regardless of whether you have unsubscribed from receiving advertising and promotional material from Rich Data Solution, you will continue to receive transactional information from us, such as information relating to your account or payment or bill information.

Do Not Track Signals

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of Websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different Websites. Our Websites do not support Do Not Track requests at this time, which means that we collect information about your online activity while you are using our Websites.

How Can I Correct or Amend Information About Me?

We want to assure you that you have access to your personal data that we collect and store. You may correct or amend information that is inaccurate by reviewing and updating your account preferences or by contacting us by email at dpo@richdatasolution.com or by mail at Rich Data Solution, Attention: Data Privacy Officer, 2740 SOUTH RD, POUGHKEEPSIE, NY 12601.

Collection and Use of Information from Children

Our Services are not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please send an email to: dpo@richdatasolution.com. You may also call +1 601-879-4436 and ask for the Data Privacy Officer, or mail your request to the attention of the Data Privacy Officer at 2740 SOUTH RD, POUGHKEEPSIE, NY 12601.

Privacy Rights

Depending on where you live, you may have certain rights with respect to your information.

Residents of certain U.S. states that have enacted individual data privacy laws (including California, Colorado, Connecticut, Utah, Virginia and such others as may be enacted from time to time), in addition to residents of the EEA, UK, or Switzerland, may be able to request:

• access to and/or a copy of certain personal information we hold about you;
• correction of inaccurate information that we have about you;
• deletion of certain personal information we have collected from you; and/or
• provide information about financial incentives that we offer to you, if any.

California, Colorado, Connecticut, Utah and Virginia residents also have certain “opt out” rights described below. Applicable law may further provide you with the right to not be discriminated against for exercising your rights.

Please note: Your rights and our responses will vary based on your state or country of residency. You may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.

If you would like information regarding your rights or would like to make a request (or if you are an authorized agent acting in accordance with applicable law), please email us at dpo@richdatasolution.com.

We will take reasonable steps to verify your identity and requests, including by verifying your account information, residency or the email address you provide. If you are an authorized agent submitting a request on behalf of another individual, we may require proof of your written authorization before processing the request.

Certain information may be exempt from such requests under applicable law such as information we retain for legal compliance and to secure our Services. We may need certain information in order to provide the Services to you; if you ask us to delete it, you may no longer be able to use the Services.

Virginia, Colorado, and Connecticut residents may appeal the denial of a request by emailing us at dpo@richdatasolution.com.

If you are a California, Colorado, Connecticut, Utah or Virginia resident, you have the right to opt out of certain processing of your personal information for cross-contextual targeted advertising under applicable law. Cross-contextual targeted advertising is when a business display ads to you based on your personal information that is collected across different businesses. We do not participate in this type of processing. Even if you opt out of this type of processing, you will still see advertising on our Websites that may be personalized for you based only on the data that the Rich Data Solution has collected about you.

Analytics. Some analytics providers we partner with may provide specific opt-out mechanisms. For example, you may opt out of having Google Analytics use your information for analytics by installing the Google Analytics Opt-out Browser Add-on. You can visit our Cookie Notice for additional information on how to opt out of certain analytics providers.

California Consumers’ Privacy Rights

This section (“California Statement”) explains rights that certain natural persons residing in the State of California (each, a “consumer”) may have under the California Consumer Privacy Act of 2018 (CCPA), as amended and expanded by the California Privacy Rights Act of 2020 (CPRA), and such rules and regulations as may be adopted from time to time implementing and interpreting such Acts (CCPA and CPRA are collectively referred to as “CCPA”). When we use the term “personal information” in this California Statement, we are using that term as CCPA defines it, which CCPA generally defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal information does not include publicly available, deidentified, or aggregate consumer information (which are all defined in CCPA).

Where we act as a “business” under CCPA (meaning we determine the manner and reasons for why we process your personal information), we may be required to disclose additional information regarding the categories of personal information we collect, the sources where we obtain that information, the purposes for why we collect that information, who we share that information with, as well as whether we sell that personal information – all of which depends on the specific service being provided.

Categories of Personal Information we collect

Depending on the nature of your relationship with us (e.g., subscriber, attendee, media partner, research partner, service provider or Rich Data Solution employee), we may collect the following categories of Personal Information about you, including:

• Identifiers such as name, postal address, email address, account name, or telephone number;
• Information that identifies, relates to or is capable of being associated with a individual, such as financial information;
• Characteristics of protected classifications under California or federal law such as race, sex/gender or marital status;
• Commercial information such as subscription history;
• Internet or other electronic network activity information such as browsing history;
• Geolocation data, available through your device, if enabled;
• Audio, electronic, or similar information;
• Professional or employment-related information;
• Education information;
• Other personal information, as described to you in this Privacy Notice, or otherwise at the point of collection; and
• Inferences drawn from any of the information identified above, including about your preferences.

Depending on your relationship with us, we may have collected each of the above categories of Personal Information about you. In addition, we may have shared one or more of these categories of Personal Information with third parties during the preceding 12 months for the business purposes described in this Privacy Notice. For each of these categories of Personal Information, please refer to the “When is personally identifiable information collected? How is your information used?” sections above for more detailed information regarding why we collect personal information and the categories of third parties with whom we may share personal information.

California residents can also request information about the categories of personal information we collect, disclose or sell or share about you; the categories of sources of such information; the business or commercial purpose for collecting, selling, or sharing your personal information; and the categories of third parties to whom we disclose personal information. Such information is also set forth in this Privacy Notice.

California residents also have the right to request that we delete your information. To make a request, you can contact us toll free at +1 601-879-4436 and ask for the Data Privacy Officer or by email to our Data Privacy Officer at dpo@richdatasolution.com or in writing to Rich Data Solution, Attention: Data Privacy Officer, 2740 SOUTH RD, POUGHKEEPSIE, NY 12601. Provide us enough information to verify your identify. We will use information you provide to us to verify your request. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as, for example, a copy of your driver’s license and/or a recent utility or credit card bill.

California residents also have certain rights regarding the “sale” or “sharing” of “personal information” (as such terms may be defined by CCPA). California residents have the right to opt out of such “sale” or “sharing” of their “personal information” in accordance with CCPA: (1) online, (2) by emailing dpo@richdatasolution.com, (3) by writing to Rich Data Solution, Attention: Data Privacy Officer, 2740 SOUTH RD, POUGHKEEPSIE, NY 12601. Once a year, California residents can also request certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year.

We will not discriminate against you because you have exercised any of your privacy rights under the CCPA.

Nevada Residents

Nevada consumers who have purchased goods or services from us may opt out of the “sale” of “covered information” as such terms are defined under Nevada law. We do not engage in such activity, but if you have questions about this you can email us at dpo@richdatasolution.com.

Users Outside of the United States and Consent to Transfer

The Websites and Services provided by Rich Data Solution are operated in the United States. If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to, stored and processed in the United States. By using the Websites or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws are not as comprehensive as those in the country where you reside or are a citizen, such as the European Union. You understand that the U.S. government can obtain access to the personal data you submit if necessary for investigative purposes (e.g., terrorism investigation). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice. We use appropriate and suitable safeguards for transferring your Personal data to the U.S.

Your EU and UK Data Subject Rights

If you are a resident of the European Economic Area (EEA) or the United Kingdom (UK), we collect and process Personal data about you only where we have a legal basis for doing so under applicable data protection law, including under the European General Data Protection Regulation (GDPR) and the UK GDPR. The legal bases will depend on the purpose for which we process your personal data. This means we collect and use your personal data only where:

• We need it to provide the services including to operate the Website
• provide customer support and personalized features and to protect the safety and security of the Website
• It satisfies a legitimate interest (which is not overridden by your rights and interests), such as for research and development, to market and promote the Website and to protect our legal rights and interests
• You give us consent to do so for a specific purpose
• We need to process your Personal data to comply with a legal obligation.

If you have consented to our use of personal data about you for a specific purpose, you have the right to change your preferences at any time.

We note that we are a “controller” for those services where we make decisions on how personal information is used in connection with our services, and we are a “processor” for those services where we only use personal information as allowed by our customers.

Where we make decisions on how personal information is used in connection with our Websites, products or services (where we are acting as a controller), we are responsible for the obligations of a “controller” under applicable laws in connection with the processing of personal information – for example, we use this Privacy Statement and other notices to provide you with information about our use of personal information, as required by law. Where we only use personal information as allowed by our customers (where we are acting as a processor), our customers are similarly responsible for the obligations of a “controller” under applicable laws in connection with the processing of personal information.

We may use your email address to send you newsletters or marketing emails. We will ask for your consent consistent with the applicable law when you first provide your Personal data. You can opt out by following the unsubscribe instructions included in these emails, or you can contact us at dpo@richdatasolution.com or in writing to Rich Data Solution, Attention: Data Privacy Officer, 2740 SOUTH RD, POUGHKEEPSIE, NY 12601.

Requesting access to your Personal data.

You have the right to request access to any Personal data we hold about you as well as related information, including the purposes for processing the Personal data, the recipients or categories of recipients with whom the Personal data has been shared, where possible, the period for which the Personal data will be stored, the source of the personal information, and the existence of any automated decision making.

Requesting correction of your Personal data.

You have the right to obtain without undue delay the rectification of any inaccurate Personal data we hold about you.

Requesting erasure of your Personal data.

You have the right to request that Personal data held about you is deleted.

Requesting restriction of processing your Personal data.

You have the right to prevent or restrict processing of your Personal data.

Requesting transfer of your Personal data.

You have the right to request transfer of Personal data directly to a third party where this is technically feasible.

Where you believe that we have not complied with our obligation under this Privacy Notice or European data protection law, you have the right to make a complaint to an EU Data Protection Authority.

Document History

March 4, 2020 Originally Published
May 25th, 2020 Amended

August 1, 2021 Amended

January 10, 2022 Amended

August 28, 2023 Amended

April 29, 2024 Amended

For any questions about this notice or to request a copy of previous versions of this notice, please direct to our data privacy officer at dpo@richdatasolution.com or in writing to Rich Data Solution, Attention: Data Privacy Officer, 2740 SOUTH RD, POUGHKEEPSIE, NY 12601.

Cookie Notice

Rich Data Solution, its subsidiaries and affiliates (collectively “Rich Data Solution” or “we”) uses cookies and other internet technologies in the management of our Websites, mobile applications and email programs in an effort to enrich your online experience with us.

What are cookies and how are they used?

“Cookies” are small text files containing small amounts of information that are sent to your computer’s browser and stored on your device when you visit a website. Upon your first visit to one of our Websites, a cookie will be sent to your computer that uniquely identifies your browser. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Many major web services use cookies to provide useful features for their users, such as letting you navigate between pages efficiently, remembering your preferences, and generally to improve the user experience. They can also help to ensure that advertisements you see online are more relevant to you and your interests. Our cookies do not contain any information that is personally identifiable.

Like many websites, Rich Data Solution uses pixel tags, also known as web beacons, clear gifs, or web bugs, which are small graphic files that allow us and third parties to monitor the use of the Websites and collect usage data. We may use pixel tags, either provided by us or by our third-party service providers and advertisers, to collect information about your visit, including the IP address of the computer that downloaded the page on which the tag appears, the pages you view, the links you click and other actions taken in connection with our Websites and use them in combination with cookies to provide offers and information of interest to you. Pixel tags help us improve our understanding of our web traffic and visitor behavior, as well as gauge the response to our promotional efforts. This usage data we collect is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as personal data.

Cookies can be set by the site or Service you are visiting (“first-party cookies”) or by a third party, such as analytics or advertising services (“third-party cookies”). Third parties may collect and use information as we have described in this Cookie Notice and our Privacy Notice and pursuant to their own privacy policies.

We use industry-standard, third-party advertising service companies to display marketing of our customers that is most relevant to you when you visit our Websites or open our emails. In some cases, we will use the information collected by our Service Providers to target and serve advertisements to our subscribers and Website visitors on other websites based on your usage of our Websites and Services. You can opt-out of rich data solution processing your personal information for targeting advertising across unrelated websites (known as ‘cross-contextual behavioral advertising’) under applicable state law by: (1) submitting this OPT-OUT FORM, (2) email dpo@richdatasolution.com, or (3) by mail to Rich Data Solution, Attention: Data Privacy Officer, 2740 SOUTH RD, POUGHKEEPSIE, NY 12601.

We do not sell or share personal information with unrelated third parties for them to use in cross-contextual behavioral advertising.

Types of cookies

Our Websites and other online Services use the following types of cookies for the purposes set out below:

Choices

Depending on where you live, you may be able to adjust your Cookie preferences at any time via a “Manage Cookies” option. You can also use the methods described below to manage certain Cookies and similar technologies. In many cases, including for Cookies, you must take such steps on each browser or device that you use. If you change or upgrade your browser or device, or delete your Cookies, you may need to use these opt-out tools again. Some Cookie-management solutions also rely on Cookies, so please adjust your browser Cookie settings carefully. We do not maintain or control the opt-out mechanisms and settings below and are not responsible for their operation.

You can find more information about Cookies and how they work, what Cookies have been set on your computer or mobile device and how to manage and delete them at http://www.allaboutcookies.org.

Browser Controls: Most browsers are initially set up to accept cookies. You may be able to disable and manage some Cookies through your browser settings. You can visit your browser’s help menu to learn more. For most browsers, you can reset your browser’s default settings to refuse all cookies or to indicate when a cookie is being sent; however, if you reject cookies, you will not be able to sign in to the Websites or take full advantage of our Websites and Services. Additionally, if you clear all cookies on your browser at any point after setting your browser to refuse all Cookies or indicate when a Cookie is being sent, you will have to again reset your browser to refuse all cookies or indicate when a Cookie is being sent. If you wish, you may disable pixel tags by setting your browser to omit images and disable JavaScript.

Mobile Settings: Your mobile device may also include settings that allow you to manage the use of Cookies, such as Limit Ad Tracking or Tracking settings in iOS and Opt-out of Ads Personalization in Android.

Analytics: To disable certain analytics Cookies, you can use the browser controls discussed above or, for some of our providers, such as Google Analytics , you can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.

Interest-Based Advertising: Most third-party advertisers offer a way to opt out of their interest-based advertising. In addition to the steps described above, you may opt-out of certain targeted advertising from participating entities by visiting the Network Advertising Initiative and Digital Advertising Alliance in the US, Digital Advertising Alliance of Canada, European Interactive Digital Advertising Alliance in the UK, European Interactive Digital Advertising Alliance, or Australian Digital Advertising Alliance.

Consequences of Deactivating Cookies

If you disable or remove Cookies, some parts of the Services may not function properly. Information may still be collected and used for other purposes, such as internal operations and to remember your opt-out preferences.

Information about specific Cookies used by our Websites

Additional Information about Hotjar Cookies used on some of our Websites

Some of our Websites use Hotjar’s behavior analytics software designed to give website owners an aggregated view of their users’ behavior while browsing their site. This provides us with the insights needed to improve the overall experience for our users. Hotjar is not designed to track individual users. All cookies used by Hotjar are Statistical Cookies. If you do not want Hotjar to collect your data, you can change your browser settings following these instructions: Hotjar – Do Not Track.

Prior Document History

May 25th, 2020 (Originally Published as part of Rich Data Solution’s Privacy Policy)
January 10, 2021 (Amended)
August 28, 2023 (Established as separate Cookie Notice)

April 29, 2024 Amended

For any questions about this notice or requests for a copy of previous versions, please direct to our data privacy officer at dpo@richdatasolution.com or in writing to Rich Data Solution, Attention: Data Privacy Officer, 2740 SOUTH RD, POUGHKEEPSIE, NY 12601.

Terms and Conditions of Use for
Rich Data Solution Websites

These Terms and Conditions of Use (the “Terms and Conditions”) apply to all Rich Data Solution, LLC and its subsidiaries’ and affiliates’ (“Rich Data Solution”) websites and digital products (each, a “Website”) and are between the user of the Website (“User”) and Rich Data Solution.

General Rules

Access to our Websites or use of our Website’s content constitutes User’s agreement with these terms and Conditions. User acknowledges that User has read these Terms and Conditions and that User accepts the terms thereof.

USER AGREES TO READ THESE TERMS AND CONDITIONS OF USE CAREFULLY BEFORE USING THE WEBSITE.

Rich Data Solution reserves the right, at its sole discretion, to change, modify, add or remove any portion of these Terms and Conditions, in whole or in part, at any time. Notification of changes in these Terms and Conditions will be posted on the Website, and User’s continued use of the Website affirmatively indicates User’s acknowledgment of such changes and User’s agreement to be bound by the Terms and Conditions as modified. Unless otherwise agreed in writing, User’s right to use the Website is not transferable and is subject to any restrictions established by Rich Data Solution. Rich Data Solution may change, suspend, or discontinue any aspect of the Website at any time, at its sole discretion, without prior notice and without liability to User or any third party for such change, suspension, or discontinuance. Rich Data Solution may also impose limits on certain features and services or restrict User’s access to parts or all of the Website without notice or liability.

SHOULD USER OBJECT TO ANY OF THESE TERMS AND CONDITIONS OR ANY SUBSEQUENT CHANGE OR MODIFICATION TO THESE TERMS AND CONDITIONS, OR SHOULD USER BECOME DISSATISFIED WITH THE WEBSITE IN ANY WAY, USER’S ONLY RECOURSE IS TO IMMEDIATELY DISCONTINUE USE OF THE WEBSITE. SO LONG AS USER CONTINUES TO USE THE WEBSITE, Rich Data Solution WILL CONTINUE TO RELY ON USER’S FULL AND UNQUALIFIED ACCEPTANCE AND COMPLIANCE WITH THESE TERMS AND CONDITIONS.

Access to the Website

User shall not have the right to sell, license, market, or lease the Website content to any party whatsoever without the prior written consent of Rich Data Solution. User shall not have the right to distribute the Website content in any manner to any third party or unauthorized user.

User hereby acknowledges that, as between Rich Data Solution and User or any party acting through User, all title to and ownership of the Website and its content remains vested in Rich Data Solution and nothing in these Terms and Conditions serves to transfer such ownership or title to User or any party acting through User. All copies and representations of content from the Website, including merged or modified portions, shall as between User and Rich Data Solution remain Rich Data Solution’s exclusive property, shall continue to be subject to these Terms and Conditions, and shall contain all Rich Data Solution copyright and other proprietary notices.

User agrees to use the Website only non-commercially, and only for User’s bona fide development or legitimate business purposes in accordance with these Terms and Conditions. User shall use all reasonable Rich Data Solution not to permit or allow the Website to be used by any party whatsoever for purposes not connected with User’s non-commercial, legitimate business purposes. User agrees to report promptly to Rich Data Solution any observed violation of the above. User agrees that the Website shall not be used in any manner or for any purpose other than the permitted purposes as expressly described in these Terms and Conditions.

User shall notify the Website’s Webmaster of any known or suspected unauthorized use(s) of the Website through User’s account, or any known or suspected breach of security, including loss, theft, or unauthorized disclosure of User’s means of access.

User may not share User’s means of access with others. User acknowledges that User is responsible for all usage or activity on User’s Website account, including such use of the account by any third party. Any fraudulent, abusive, or otherwise illegal activity may be grounds for termination of User’s account, at Rich Data Solution’s sole discretion, and User may be referred to appropriate law enforcement agencies. User agrees to indemnify, defend, and hold Rich Data Solution harmless against liability for any and all use of User’s account.

Authorized Usage of Website Content

The contents of the Website are intended for the benefit of User’s legitimate non-commercial business. Non-commercial use does not include the use of Content without prior written consent from Rich Data Solution in connection with: (1) the development of any software program, including, but not limited to, training a machine learning or artificial intelligence (AI) system; or (2) providing archived or cached data sets containing Content to another person or entity. All materials displayed on the Website (including, but not limited to articles, reports, photographs, images, illustrations, audio clips and video clips, and including caption information, keywords, or other metadata) (each and collectively, the “Content”) are protected by copyright, and owned or controlled by Rich Data Solution or the party credited as the provider of the Content, software, or other materials. Users shall abide by all copyright notices, information, or restrictions contained in any of the foregoing Content accessed through the Website. User acknowledges that he/she has no claim of ownership or other right to any Content by reason of its access, use, or otherwise.

The Website is protected by copyright as a collective work and/or compilation, pursuant to U.S. copyright laws, international conventions, and other copyright laws. Copying or storing of any Content for other than User’s legitimate non-commercial business end-use is expressly prohibited without the prior written permission of Rich Data Solution or the copyright holder identified in the individual Content’s copyright notice. IN NO EVENT SHALL USER ALTER OR DELETE ANY AUTHOR ATTRIBUTION OR COPYRIGHT NOTICE.

Except as specifically provided in these Terms and Conditions, User may not modify, publish, transmit, participate in the transfer or sale of, reproduce, create derivative works from, distribute, display, or in any way exploit, any of the the forgoing Content, software, materials, or the Website in whole or in part.

You may not access or use, or attempt to access or use, the Services to take any action that could harm us or a third party. You may not use the Services in violation of applicable laws, including export controls and sanctions, or in violation of our or any third party’s intellectual property or other proprietary or legal rights. You further agree that you will not attempt (or encourage or support anyone else’s attempt) to circumvent, reverse engineer, decrypt, or otherwise alter or interfere with the Services, or any content of the Services, or make any unauthorized use of the Services. Without Rich Data Solution’s prior written consent, you shall not:

(1) access any part of the Services, Content, data or information you do not have permission or authorization to access or for which Rich Data Solution has revoked your access;

(2) use robots, spiders, scripts, service, software or any manual or automatic device, tool, or process designed to data mine or scrape the Content, data or information from the Services, or otherwise use, access, or collect the Content, data or information from the Services using automated means;

(3) use the Content for the development of any software program, including, but not limited to, training a machine learning or artificial intelligence (AI) system, or for any technologies designed for or intended for the identification of natural persons;

(4) use services, software or any manual or automatic device, tool, or process designed to circumvent any restriction, condition, or technological measure that controls access to the Services in any way, including overriding any security feature or bypassing or circumventing any access controls or use limits of the Services;

(5) cache or archive the Content (except for a public search engine’s use of spiders for creating search indices);

(6) take action that imposes an unreasonable or disproportionately large load on our network or infrastructure; and

(7) do anything that could disable, damage or change the functioning or appearance of the Services, including the presentation of advertising.

Engaging in a prohibited use of the Services may result in civil, criminal, and/or administrative penalties, fines, or sanctions against the user and those assisting the user.

No use is permitted which benefits any party other than Rich Data Solution or User.

Rich Data Solution products referenced in a Rich Data Solution digital product or website are either trademarks or registered trademarks of Rich Data Solution. Other featured logos, product and company names are or may be service/trademarks of their respective owners.

User-Generated Content

You still own the content that you provide to Rich Data Solution under this agreement, but you the User grant Rich Data Solution an irrevocable and perpetual license to use any User-generated content posted on the Website by User, including the right to sub-license such User-generated content.

User represents and warrants that all content submitted to Rich Data Solution by User is owned by User or that they have the rights to submit to Rich Data Solution and that this submission is not in violation of any law, contractual restrictions, or other third party rights and is not obscene, threatening, harassing, defamatory, libelous, invasive of privacy, infringing of intellectual property rights, or otherwise injurious to third parties or objectionable.

Warranty and Availability of Service and Links

Neither Rich Data Solution nor any of the Websites represents or endorses the accuracy or reliability of any advice, opinion, statement, or other information displayed, downloaded, uploaded, or distributed through the Website by any user, information provider, or any other person or entity. User acknowledges that any reliance upon any such opinion, advice, statement, or information shall be at User’s sole risk. Rich Data Solution reserves the right but not the obligation, in its sole discretion, to correct any errors or omissions in any portion of the Website.

THE WEBSITE IS DISTRIBUTED ON AN “AS IS” AND “AS AVAILABLE” BASIS WITHOUT WARRANTIES OF ANY KIND WHATSOEVER, WHETHER EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION WARRANTIES OF TITLE, NON-INFRINGEMENT, OR MERCHANTABILITY, OR FITNESS FOR A PARTICULAR PURPOSE, OR THAT THE WEBSITE OR ANY MATERIALS OBTAINED THROUGH THE WEBSITE ARE VIRUS-FREE OR ERROR-FREE. NEITHER Rich Data Solution NOR ANYONE ELSE INVOLVED IN CREATING, PRODUCING, OR DELIVERING THE WEBSITE CONTENT SHALL BE LIABLE UNDER ANY THEORY OF LAW (INCLUDING NEGLIGENCE) FOR ANY LOSS OR DAMAGE THAT MAY ARISE IN CONNECTION WITH THE FURNISHING, PERFORMANCE, USER’s INABILITY TO USE, OR USER’s USE OF THE WEBSITE, INCLUDING ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, ECONOMIC, LOST PROFIT, OR CONSEQUENTIAL DAMAGES, OR OTHER KIND OF LOSS OR DAMAGE WHATSOEVER, EVEN IF Rich Data Solution HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGE. IN NO EVENT SHALL USER BE ENTITLED UNDER ANY THEORY OF LAW (INCLUDING NEGLIGENCE) TO ANY MONETARY DAMAGES IN EXCESS OF ANY FEE PAID BY USER FOR USE OF THE WEBSITE DURING THE 3-MONTH PERIOD PRECEDING THE EVENT GIVING RISE TO THE CLAIM FOR DAMAGES. USER’s RIGHT TO MONETARY DAMAGES IN SUCH AMOUNT SHALL BE IN LIEU OF ALL OTHER REMEDIES THAT USER MAY HAVE OTHERWISE HAD AGAINST Rich Data Solution. USER EXPRESSLY ACKNOWLEDGES THAT USE OF THE WEBSITE IS AT USER’s SOLE RISK.

EXTERNAL LINKS DISCLAIMER

Our Sites may contain (or you may be sent through the Sites) links to other websites or content belonging to or originating from third parties or links to websites and features in banners or other advertising. Such external links are not investigated, monitored, or checked for accuracy, adequacy, validity, reliability, availability, or completeness by us. WE DO NOT WARRANT, ENDORSE, GUARANTEE, OR ASSUME RESPONSIBILITY FOR THE ACCURACY OR RELIABILITY OF ANY INFORMATION OFFERED BY THIRD-PARTY WEBSITES LINKED THROUGH OUR SITES OR ANY WEBSITE OR FEATURE LINKED IN ANY BANNER OR OTHER ADVERTISING. WE WILL NOT BE A PARTY TO OR IN ANY WAY BE RESPONSIBLE FOR MONITORING ANY TRANSACTION BETWEEN YOU AND THIRD-PARTY PROVIDERS OF PRODUCTS OR SERVICES.

PROFESSIONAL DISCLAIMER

Our Sites do not contain professional advice of a technical nature. Any technical information contained on our Sites are provided for general informational and educational purposes only and is not a substitute for professional advice. Accordingly, before taking any actions based upon any such information, we encourage you to consult with the appropriate professionals. We do not provide any kind of technical advice. THE USE OR RELIANCE OF ANY INFORMATION CONTAINED ON OUR SITES IS SOLELY AT YOUR OWN RISK.

AFFILIATES DISCLAIMER

Our Sites may contain links to affiliate websites, and we receive an affiliate commission for any purchases made by you on the affiliate website using such links.

We are a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for us to earn advertising fees by linking to Amazon.com and affiliated websites.

TESTIMONIALS DISCLAIMER

Our Sites may contain testimonials by users of our products and/or services. These testimonials reflect the real-life experiences and opinions of such users. However, the experiences are personal to those particular users, and may not necessarily be representative of all users of our products and/or services. We do not claim, and you should not assume, that all users will have the same experiences. YOUR INDIVIDUAL RESULTS MAY VARY.

The testimonials on our Sites are submitted in various forms such as text, audio and/or video, and are reviewed by us before being posted. They appear on the Site verbatim as given by the users, except for the correction of grammar or typing errors. Some testimonials may have been shortened for the sake of brevity where the full testimonial contained extraneous information not relevant to the general public.

The views and opinions contained in the testimonials belong solely to the individual user and do not reflect our views and opinions. We are not affiliated with users who provide testimonials, and users are not paid or otherwise compensated for their testimonials.

Provisions

These Terms and Conditions shall be construed and enforced in accordance with Tennessee law. Any action to enforce these Terms and Conditions shall be brought in the federal or state courts located in Nashville, Davidson County, Tennessee.

Any rights not expressly granted to User in these Terms and Conditions are reserved to Rich Data Solution.

Any failure by Rich Data Solution to enforce any provision of these Terms and Conditions shall not be construed as a continuing waiver of any rights under such provision.

These Terms and Conditions represent the entire agreement between Rich Data Solution and User concerning User’s use of the Website and supersede any prior understanding or agreement whether oral or written.

Subscriptions

By submitting your email address and other subscription details, you are making an offer to us to enter into a contract. By entering into a subscription, registering for an account, signing up for our webcasts, white papers or any other content, you will be contracting with Rich Data Solution, LLC or one of its subsidiaries or affiliates. A contract is formed when we have accepted your offer, at which point we will provide the product or services that you have requested. Rich Data Solution reserves the right to reject any offer at its sole discretion, for any or no reason, and if there was payment, we will refund you the subscription fees paid.

Comment Policy

The “Comments” sections found on many Rich Data Solution websites are intended to be a forum for productive, thoughtful, and considerate discussion about topics covered on our sites (“Interactive Services”). We encourage our commenters to start a dialogue. Being part of a community means expressing differing views with others. But please do so respectfully.

When commenting rules are broken, our site moderators have discretion to suspend or ban any user without notice, depending on the severity of the infraction. The content of comments falls under the discretion of the moderators whether or not it is explicitly outlined under the guidelines.

Commenting Rules

• Stay on topic. Discuss the facts, issues and opinions at hand.
• Be civil. Threats, hate speech, offensive language and defamatory comments are not tolerated. Personal attacks on staff members, other commenters or the interview subjects are not permitted.
• Do not post personal information about yourself or others.
• Don’t troll. Users who post disruptive or repetitive statements that hijack or derail the conversation may see their comments removed and, if applicable, their posting privileges revoked.
• Discussions focused upon someone’s sexuality or physical impairments are prohibited.
• Inappropriate religious and political threads may be removed.
• No advertising or spam content. Comments that include code or hyperlinks may not be posted.
• We reserve the right to remove any information or material that is unlawful, threatening, abusive, libelous, defamatory, obscene, vulgar, pornographic, profane, indecent or otherwise objectionable.

We reserve the right to permanently ban any user who violates these terms and conditions.

Comments are evaluated by our moderators, as well as algorithms programmed to look for offensive language and phrases. Comments are not enabled on all website pages based on our internal guidelines.

Please refer to these community guidelines if you have any questions.

Using the System

To post a comment, you must be logged in to the site.

Upon registering, you must provide your first and last name, which will appear publicly on your submissions to our site. We reserve the right to unpublish any comment if there is any uncertainty about the author’s identity. Stealing another person’s identity is a serious offence.

If you see an objectionable post, please flag the comment to alert the site moderators. Flagged comments are reviewed by moderators and removed if the comments are contrary to our guidelines.

You may mute another commenter using our commenting system, which renders the commenter’s posts invisible in your feed and under any articles the commenter has engaged in. To mute a commenter, click on their profile avatar and find the mute option. You can manage muted commenters under the “Community” tab in your profile.

We reserve the right to edit your comments for clarity and/or to republish them elsewhere on or in our properties.

By commenting you agree to adhere to our Community Content Standards.

Handling Rules Violations

Your comment may be removed from the website. Deletion comes without notice.

Repeat offenders and fake profiles may be banned without notice. We reserve the right to ban offenders based on our own judgment. Our decisions are final.

Reliance

The information presented on or through any Rich Data Solution website, including the availability of user comments, is made available solely for general information purposes. We do not warrant the accuracy, completeness, or usefulness of this information. Any reliance you place on such information is strictly at your own risk. We disclaim all liability and responsibility arising from any reliance placed on such materials by you or any other visitor to Rich Data Solution websites, or by anyone who may be informed of any of its contents.

Community Content Standards

These content standards apply to any and all User Contributions of the Interactive Services. User Contributions must in their entirety comply with all applicable federal, state, local, and international laws and regulations. Without limiting the foregoing, User Contributions must not:

• Contain any material that is defamatory, obscene, indecent, abusive, offensive, harassing, violent, hateful, inflammatory, or otherwise objectionable.
• Promote sexually explicit or pornographic material, or violence, or discrimination based on race, sex, religion, nationality, disability, sexual orientation, or age.
• Infringe any patent, trademark, trade secret, copyright, or other intellectual property or other rights of any other person.
• Violate the legal rights (including the rights of publicity and privacy) of others or contain any material that could give rise to any civil or criminal liability under applicable laws or regulations or that otherwise may be in conflict with our Terms of Use and our Privacy Policy.
• Be likely to deceive any person.
• Promote any illegal activity, or advocate, promote, or assist any unlawful act.
• Cause annoyance, inconvenience, or needless anxiety, or be likely to upset, embarrass, alarm, or annoy any other person.
• Impersonate any person or misrepresent your identity or affiliation with any person or organization.
• Involve commercial activities or sales, such as contests, sweepstakes, and other sales promotions, barter, or advertising.
• Give the impression that they emanate from or are endorsed by us or any other person or entity, if this is not the case.

If you believe that any User Contributions violate your copyright, please send us a notice of copyright infringement in accordance with the below instructions to legal@richdatasolution.com. It is the policy of the Company to terminate the user accounts of repeat infringers.

Reporting Claims of Copyright Infringement

We take claims of copyright infringement seriously. We will respond to notices of alleged copyright infringement that comply with applicable law. If you believe any materials accessible on or from this site (the “Website”) infringe your copyright, you may request removal of those materials (or access to them) from the Website by submitting written notification to our copyright agent designated below. In accordance with the Online Copyright Infringement Liability Limitation Act of the Digital Millennium Copyright Act (17 U.S.C. § 512) (“DMCA”), the written notice (the “DMCA Notice”) must include substantially the following:

• Your physical or electronic signature.
• Identification of the copyrighted work you believe to have been infringed or, if the claim involves multiple works on the Website, a representative list of such works.
• Identification of the material you believe to be infringing in a sufficiently precise manner to allow us to locate that material.
• Adequate information by which we can contact you (including your name, postal address, telephone number, and, if available, email address).
• A statement that you have a good faith belief that use of the copyrighted material is not authorized by the copyright owner, its agent, or the law.
• A statement that the information in the written notice is accurate.
• A statement, under penalty of perjury, that you are authorized to act on behalf of the copyright owner.
• Our designated copyright agent to receive DMCA Notices is: Chief Administrative and Legal Officer Rich Data Solution 2740 SOUTH RD, POUGHKEEPSIE, NY 12601 – Phone +1 601-879-4436 – email legal@richdatasolution.com

If you fail to comply with all of the requirements of Section 512(c)(3) of the DMCA, your DMCA Notice may not be effective.

Compliance Concerns and Reporting

Rich Data Solution is committed to operating with integrity and in full compliance with laws, regulations and policies. Our foundational values of honesty, integrity, and respect for people are essential guides to the way we act internally among our team of employees, investors, contributors and suppliers, and externally with our stakeholders, who include our clients, audience and professional community. For us, that means we are truthful and sincere, we act consistent with moral and ethical principles, and we value each person’s unique capabilities and qualities, with open-minded consideration for their rights, feelings, and traditions.

These values along with our core value of accountability reflect our commitment to a strong compliance culture as a non-negotiable foundation of how we do business. More than words on paper, our values are actionable and we are prepared to do what is necessary to ensure that EBM is managed in line with our commitment. You can help us achieve this goal.

The Ethics and Compliance Hotline is a dedicated channel for anonymous and confidential communication that facilitates reporting of possible illegal, unethical or improper conduct when the normal channels of communication have proven ineffective or impractical under the circumstances. A toll-free Compliance Hotline or Confidential Email is available for reporting any ethical or compliance concerns.

The Hotline is available to EBM employees, as well as clients, contractors, vendors and other stakeholders in a business relationship with EBM. If you are unsure about where to go with your concerns, or you feel uncomfortable reporting through normal channels of communication, or wish to raise the issue anonymously, you should access the Ethics and Compliance Hotline.

All reports to the Compliance Hotline are investigated and handled in a confidential manner by trained individuals. Callers may remain anonymous or leave their contact information if they so choose. EBM relies on this reporting information to confirm or improve its processes and practices. EBM prohibits retaliation against anyone who, in good faith, reports a possible violation or who participates in an investigation, even if sufficient evidence is not found to substantiate the concern, EBM will take appropriate action against any individual determined to be engaging in retaliatory conduction.

IMPORTANT: If your message is not related to compliance, please contact our Consumer Services team. www.richdatasolution.com/contact

How to report a compliance concern?

EBM Ethics and Compliance Hotline is available any time (24/7, 365 days a year)

• You can choose to call a toll-free phone number, +1 601-879-4436, and leave a message (anonymously or confidentially) or send a confidential email to legal@richdatasolution.com
• We take all concerns seriously and will take the appropriate action on each report. We will keep you informed on our progress while processing your concern.

• We are committed to improving our Ethics and Compliance Hotline and compliance reporting system and reserve the right to make changes in the future.

What happens after I have sent my report?

1. Acknowledgement

If you provide confidential contact information, we will acknowledge receipt of your report within five (5) working days. It may take longer if your report is sent during a public holiday. If your initial report does not include enough evidence, we will get in touch to ask you to provide more evidence.

2. Triage and Escalation

Each report we receive is studied carefully. We will open a case if your report is credible and includes enough evidence. The investigation will be led by our legal department. Reports that contain serious allegations will be escalated to our Chief Legal Officer. Chief Legal Officer will be informed when a report involves allegations of:

• dishonesty, criminal activity, antitrust /competition law, or issues involving revenue recognition, corruption, bribery or significant fraud
• misconduct by members of a Rich Data Solution senior leadership member
• matters that are likely to negatively affect the reputation or public image of Rich Data Solution.

3. Confidential investigation

The investigation will be handled with consistency and confidentiality – we will only involve people who need to be involved. Our compliance team may conduct confidential interviews with employees, contractors or anybody they feel is relevant to the investigation.

4. Decision and reply to you

After reviewing all the findings of our investigation, we will decide if a breach has taken place, and, if that is the case, take action. If you have provided contact information, you will be informed accordingly.

IMPORTANT NOTICE

Non-retaliation commitment: Rich Data Solution prohibits retaliation of any type against an employee who brought forward a concern in good faith. Anyone who attempts to retaliate against an employee for reporting in good faith may face disciplinary action, including the possibility of dismissal. Rich Data Solution also protects the rights of the person accused.

What is appropriate to report to our Ethics and Compliance Hotline?

In order to facilitate actionable and effective investigations, please include a detailed description of the incident (who, what, when, how) and supporting evidence (e.g. copies of documents, screenshots, or names of witnesses) that can corroborate your report. Please note that general assertions cannot be investigated.

Appropriate reasons to contact our Ethics and Compliance Hotline include:

• Suspected violations of our Company values, policies, or procedures
• Questionable accounting, violations of internal accounting controls, or any other auditing or financial matters, or the reporting of fraudulent financial information
• Suspected violations of law or fraudulent activities other than Fraudulent Auditing and Accounting Activities
• To receive interpretative guidance on provisions of the company’s policies, procedures or code of ethics
• To report quality control or workplace safety concerns
   

Beware of Fraudulent Recruiting Advertisements

Job Applicants should be aware of job offer scams perpetrated through the use of the Internet and social media platforms. The scammers frequently misappropriate and use a company’s logo and photos of its executives to give the appearance of legitimacy. The scam preys upon those seeking employment and uses false and fraudulent offers of employment with employers, such as Rich Data Solution, to steal from the victims. Rich Data Solution believes that one of the best ways to put a stop to these types of scams is to make you aware of it.

Rich Data Solution never requires any job applicants to pay money to anyone (Rich Data Solution, its employees or anyone else) as part of the job application or hiring process. If someone asks for money or offers to send you a check for training, equipment, etc. as part of a recruiting process, they do not work for or represent Rich Data Solution and are likely seeking to defraud you.

Rich Data Solution’s job recruitment process involves in person and/or telephonic interviews in most cases and never interviews job applicants through chat rooms (such as Google Hangouts), or through instant messaging systems. In addition, Rich Data Solution’s job recruiting staff sends email communications to job applicants from “@richdatasolution.com” or “@richdatasolution.com” email accounts only.

How to Recognize Potential Recruiting Fraud

The individuals who perpetrate frauds like this are continuously changing and evolving their methods, and one of the most important defenses is healthy skepticism based on the discussion above. Despite the fact that Rich Data Solution cannot predict all the ways scammers might operate in the future, the following is a non-exclusive list of warning signs of recruiting fraud:

• You are asked to provide credit card, bank account number(s) or other personal financial information as part of the “job application” process.
• The position requires an initial monetary investment, such as a payment by wire transfer.
• The contact email address contains a domain other than “@richdatasolution.com” or “@richdatasolution.com”, such as “@live.com,” “@gmail.com,” “@yahoo.com,” “@outlook.com,” or another personal email account. Or email correspondence is from an email address that is similar to an official Rich Data Solution address but differs by one or more characters.
• The posting includes spelling errors, grammatical errors, syntax errors, or otherwise appears to have been written by someone not fluent in English.
• The open position does not appear on the company’s website listing of job positions.
• The supposed “employer” contacts you by phone or through a chat room or instant messaging service and gives no way to call them back or the number they do give is not active or goes only to a voicemail box. For example, such supposed “employers” often direct that you “meet” them in chat rooms at specific times.
• You are offered a payment or “reward” in exchange for allowing the use of your bank account (e.g., for depositing checks or transferring money related to promised employment).
• You are asked to provide a photograph or other personal identification of yourself.
• The job posting focuses on the amount of money supposedly to be made or reflects initial pay that is high compared to the average compensation for the type of job.

What You Can Do

• If you believe you have been the victim of a job recruiting fraud scam, you can:File an incident report at http://www.cybercrime.gov
• Call the Federal Trade Commission at 1-877-FTC-HELP (1-877-382-4357) or file a complaint with the FTC online at https://www.ftccomplaintassistant.gov/#crnt&panel1-1
• File a complaint with the Federal Bureau of Investigation at https://ic3.gov
• Contact your local police to report the fraud
• Contact your bank or credit card company to close your account and dispute any charges related to the fraud charges.