Updated October 2, 2019
RUBY RECEPTIONISTS, INC.
This Policy applies to personal information about individuals and does not apply to the information collected, used or disclosed with respect to corporate or commercial entities. This Policy does not impose any limits on our collection, use or disclosure of the information exempted under applicable privacy legislation.
By visiting the Site, using or downloading the App, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site, App, or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the provisions regarding resolution of disputes. The Ruby Terms of Service are incorporated by reference into this Policy.
If you are a registered user, you will have access to a customer portal or dashboard (each, a “Portal”). Please see the section below entitled Customer Portal for a description of the information that we collect through the portal or dashboard and how we use and disclose that information.
Limits on Collection, Use and Disclosure of Personal Information
We will limit the collection of personal information to that which is reasonable and necessary. We may also collect personal information as authorized or required by law. Your personal information will only be used or disclosed for the purposes set out below and as authorized or required by law.
The Information We Collect About You
We collect information about you directly from you and from other persons, and automatically through your use of our Site, App, or Services.
Information You Provide Directly To Us. The information we collect from you depends on how you use our Services. To create an account to sign up to use our Services, you must provide your name, email address, company name, in some cases, a password, and payment information, such as your debit/credit card number and billing address. If you request information from us through the chat feature on our Site or a contact form, we will collect information, including your contact information, which may include your name, email address, telephone number, company name, any other professional information that you provide, as well as the scope of your communication with us.
When you use our App, you have the option of synching your contact and calendar with the App. As discussed in the “How we Use Your Information” section below, we use this information to provide our Services to you and to improve the quality of those Services. For example, if caller ID indicates to one of our representatives that you know the caller, we may answer in a more familiar tone or change the questions that we ask before transferring the incoming call to you.
Information We Collect From Other Persons. Your employer may add employees to the Portal so that multiple persons within your company will have access to our Services. If your employer chooses to do so, then we also will have your business contact information and any other information that your employer chooses to provide to us.
As permitted by applicable law, we obtain contact information about prospective customers from professional associations, market research, and marketing companies, which we may append to information that we have previously collected about you. We use this information for our own marketing purposes.
We have relationships with unaffiliated websites that allow us to share on our Site content, such as reviews, that you post to their sites. We may receive from those unaffiliated websites your username, the content of your review and other information that you post to their websites. For more information, see “User Generated Content” below.
Job Applicants. When you apply for a position through the careers section of our Site, we request information required to process your application such as your name, contact information, education and professional history. We also request information such as demographic information, which you are not required to provide.
Information We Collect in our Capacity as a Service Provider. When we act in our capacity as a service provider, whether through the provision of chat, receptionist, or any other requested services, we use the information for the purpose of providing the requested service to the customer. In addition, if you use our App, we may request various permissions from your device in order to provider our Services. For example, we may request permission to access your contacts, calendar, microphone, phone and storage. When we act in our capacity as a service provider, whether through the provision of chat, receptionist, or any other requested services, we collect and analyze data and other information relating to the provision, use and performance of various aspects of our services and related systems and technologies. We use such information and data to improve and enhance our services and for other development, diagnostic and corrective purposes in connection with the Services and others of our offerings. We also use such information and data for marketing purposes. In addition, we may disclose such information and data in aggregate, anonymized or other de-identified form for any purpose.
Information We Collect Automatically. We automatically collect the following information about your use of our Services through cookies, web beacons, and other technologies, including technologies designed for mobile apps. Our Services access geolocation data in order to customize the Services that we provide to you.
We collect the following information automatically when you visit our Site:
• your domain name;
• your device ID;
• your IP address;
• your MAC address;
• your browser type and operating system;
• your cursor movement and text box entries;
• web pages you view on the Site and links you click on the Site;
• the length of time you visit our Site and/or use our Services;
• geolocation information;
• hashed identifiers derived from email addresses; and
We collect the following information automatically when you use our App:
• your device name and model; operating system type, name, and version;
• your activities within the App; and
• the length of time that you are logged into our App.
We combine the information that we collect automatically with other information we collect about you, including your personal information. In some cases, we maintain this information in the aggregate. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
How We Use Your Information
As permitted by applicable law, we use your information, including your personal information, for the following purposes:
• Service Providers. We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. These service providers include but are not limited to marketing companies, companies that host our Site or App, or provide IT services to support either, platforms we use to help us manage our data and companies that assist us in processing job applications that you submit through our Site. In addition, we share your information with the case management and other administrative software platforms used by our customers. The type of information that we provide to the service providers will depend on the purpose of the service that they provide to us.
• Ad Networks. We disclose the information that we collect to Advertisers (as defined below) in order to assist us in providing targeted advertising to you. For more information, see “Ad Networks” below.
• Affiliates. We disclose the information we collect from you to our affiliates or subsidiaries. If we do disclose your personal information to our affiliates or subsidiaries, their use and disclosure of your personal information will be subject to this Policy.
• Ruby Users. Your user name, or other name you choose, and any information that you post to our Site, including, without limitation, reviews, comments, and text will be available to, and searchable by, all users of the Site and Services.
• Professional Associations. If you are a member of a professional association, such as an attorney bar association, we may pay a fee to that association if you sign up to use our Services. We share information about you with these associations, such as your name and the name of your employer. Please note, however, that we do not share customer information provided through the Portal with professional associations.
As permitted by applicable law, we also disclose information in the following circumstances:
• Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third party advisors, including attorneys and consultants.
• In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
• Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with non-affiliated entities for marketing, advertising, research or similar purposes.
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
• Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.
• Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising on sites provided by other entities.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track the activities of Site visitors and app users, help us manage content, and compile statistics about Site usage. We and our service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
• Yahoo Analytics: We use third-party web beacons from Yahoo to help analyze where visitors go and what they do while visiting our Site and Services. Yahoo may also use anonymous information about your visits to our Site and other sites in order to improve its products and services and provide advertisements about goods and services of interest to you.
Cross-Device Use. We and our service providers, including Google, may use the information that we collect about you (whether directly from our Site, from our mobile applications, through your device(s), or from a service provider or other entity) to help us and our service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer). As permitted by applicable law, we and our service providers also may use the cross-device use and other information we learn about you to serve targeted advertising on your devices, to track leads generated, and to send you emails. To opt-out of cross-device advertising, you may follow the instructions set forth in the Ad Networks section below. Please note: if you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt-out of each browser or device that you use.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Ad Networks section below.
We use network advertisers, sponsors, and/or traffic measurement services (collectively, in this Policy, “Advertisers”), to serve advertisements on other websites or other media (e.g., social networking platforms). This enables us and these Advertisers to target advertisements to you for products and services in which you might be interested. The Advertisers we use include:
• Google/DoubleClick: For more information, see Google’s Privacy Information and Ads Settings;
• Google Analytics Advertising, including its Remarketing, and Reviews features: For more information: see “Analytics” above); and
• Microsoft: In relation to our use of Microsoft Advertising’s Universal Event Tracking (UET) feature, Microsoft may collect personal information and share it with Microsoft Advertising. For more information, see https://privacy.microsoft.com/en-us/privacystatement.
Users in the United States and Canada may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page or the Digital Advertising Alliance of Canada (“DAAC”) website for information about opting out of interest-based advertising and choices regarding having information used by DAA companies and DAAC companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page or the DAAC website will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site, Services, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA, NAI or DAAC websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info, the NAI’s website at www.networkadvertising.org, or the DAAC’s website at https://youradchoices.ca/en/tools.
User Generated Content
We have relationships with certain unaffiliated websites, including TrustPilot, that allow us to share reviews and other content that you post to their sites on our Site. In accordance with the terms of our agreement with those unaffiliated websites, we will post content that you post to their websites, including your username and the content of your review, on our Site. Your content that we post may become public and Ruby cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.
Links to Other Websites
Our Site and Services may contain links to non-affiliated websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites.
Security of My Personal Information
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Access to My Personal Information
You may modify personal information that you have submitted by emailing or calling us at the contact details provided below. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or App for a period of time.
What Choices Do I Have Regarding Use of My Personal Information?
As permitted by applicable law, we may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.
Children Under 13
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
Registered users have access to their accounts through our Portal made available on our Site and App. We collect the information that you submit to us through the Portal (e.g., requests to add/modify services) and associate it with your account. We use that information for purposes consistent with this Policy and our agreements with our customers.
Specific Considerations for Canadian Individuals
Location of Service Providers, Hosting and Servers. Our service providers may be located outside of the country in which you are located, and our servers are currently located in the United States. You acknowledge that your personal information may be processed and stored in foreign jurisdictions and that governments, courts, law enforcement or government or regulatory agencies in the United States, Canada and elsewhere may be able to access or obtain disclosure of your personal information under a lawful order or otherwise through the laws of the applicable foreign jurisdiction, irrespective of the safeguards we have put in place to protect your personal information. You may contact us using the details provided below to obtain information about our policies and practices regarding our transfer of data or use of service providers in different jurisdictions.
Security Measures. We will take reasonable measures, through contractual or other means, so that suppliers and agents who assist in providing the Services use reasonable precautions to protect your personal information.
Access Rights. Upon written request and identity authentication, we will provide you with your personal information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within thirty (30) days or provide written notice where additional time is required to fulfil the request.
In some situations we may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purpose of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm our competitive position. We may also be prevented by law from providing access to certain personal information. When we refuse an access request, we will notify you in writing, document the reasons for refusal and outline further steps that are available to you.
Choices. You may withdraw your consent to our collections, uses and disclosures of your information at any time, subject to legal, contractual and other restrictions, provided that you give reasonable notice of consent withdrawal to us. On receipt of notice of consent withdrawal, we will inform you of the likely consequences of that consent withdrawal, which may include our inability to provide certain services for which that information is necessary.
Accuracy of Personal Information. We will make a reasonable effort to ensure that your personal information that we are using or disclosing is accurate and complete. In most cases, we rely on you to ensure that your information is current, complete and accurate. If you demonstrate that your personal information is inaccurate or incomplete, we will amend the information as required. If appropriate, we will send the amended information to unaffiliated entities to whom the information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under such entity’s control with a note that the correction was requested, but not made.
Retention. We will keep your personal information for as long as necessary in connection with the purposes identified above or as permitted or required by law. You must notify us if you no longer want us to retain your information. We will destroy, erase or make anonymous, documents or other records containing your personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retaining the information and retention is no longer necessary for a legal or business purpose. We will take due care when destroying personal information so as to prevent unauthorized access to the information.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and App. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and App.