When you register for an Axios Local Social Club powered by DNNR.io, two different privacy policies apply:

The Axios Privacy Policy, which governs how Axios handles personal data it collects or receives in connection with your participation in an Axios Local Social Club or your use of other Axios services.
The River Privacy Policy, which governs how River Platform Company, the provider of DNNR.io, handles personal data it collects or receives in connection with your use of the DNNR platform.

Copies of both privacy policies are available below.

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Axios Privacy Policy

Last updated Jan 1, 2025

1 big thing: This Privacy Policy explains how Axios Media Inc. and its affiliates (“Axios”) handle the personal information and data we collect from or about our users.

This Privacy Policy applies to all Axios Services, including our website (www.axios.com), events, and newsletters. It also applies to any other Services we offer now or in the future that link to or reference this Privacy Policy. This Privacy Policy is incorporated by reference into our Terms of Use Agreement.

Why it matters: Understanding our readers helps us build an indispensable news platform that helps people to get smarter, faster. It also helps us sell advertising sponsorships, which allows us to keep most of our Services paywall-free.

Yes, but: This doesn't serve as a decree to collect or use your data without limits. We strive to be respectful with what personal information we collect and how we use it, and we are constantly pushing ourselves to a higher standard concerning privacy.

Be smart: This Privacy Policy describes how we collect information about you, how we use it, who we share it with, and how you can exercise your rights and choices regarding the use and sharing of your information.

Situational awareness: If we update this Privacy Policy, we’ll revise the “Last updated” date at the top of the page. Changes become effective when posted. Your continued use of the Services indicates your acceptance of the revised Privacy Policy.

The bottom line: Your online privacy matters. You should read this Privacy Policy carefully and take whatever steps you feel are appropriate to protect your online privacy. If you have questions, you can reach us at privacy@axios.com.

Go deeper:

What sort of personal information does Axios collect?

How do we get your personal information?

How do we use your personal information?

How do we share your personal information?

What else should you know?

Your Privacy Rights.

Submit an access, correction, or deletion request.

‍Opting out of targeted advertising and cross-site marketing.

Remember, you have choices.

The bottom line.

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What sort of personal information does Axios collect?

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Axios collects the following categories of information:

Contact Information (like your name and email address)
Identifiers that relate to you and your device (like your email address, IP address or Device Id)
Information about the transactions you conduct through our Services, including payment information (if you pay for Services like Axios Pro or a Membership Program)
Information about how you interact with our Services and the advertising on our Services, including cookie data.
Non-precise geolocation data (using IP address or city information you provide)
Professional information (like your job title)
Third party information from select data providers (more details below)
Inferences about you based on the above information

We may also collect other categories of information not covered by the above if you voluntarily provide it in an email to our newsroom or in response to a survey or other user experience research. This might include characteristics of protected classes or categories of information that are considered “sensitive” under certain U.S. state privacy laws if you choose to share them (for example, details about your race or ethnicity, sexuality, immigration status, political or religious views). Otherwise, we don’t knowingly collect personal information about our users that is typically categorized as “sensitive.”

How do we get your personal information?

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We get information directly from you through your interactions with us and our website. For example:

When you register for newsletters, we collect your email address and the topics you're interested in.
When you request information about Axios Services, submit a tip, complete a survey, or otherwise contact us, we collect the information you provide, such as your contact information, company name, and the content of the communication.
When you register for a Service or complete a payment, we collect your account information, such as your email address and password, and any information needed to complete the transaction, including your name and payment card number.
When you complete a survey, enter a sweepstakes or contest, or sign up for an event, we collect your contact information and any other information you provide, like demographic or professional information.
When you visit our website, or engage with a newsletter, we use cookies, pixel tags, and other online trackers to understand how you interact with our Services. This includes information like what type of device you're using, which links you clicked, and what ads you view and engage with.
When you refer our Services to a friend or colleague through any referral program or feature we may offer now or in the future, we may collect the email address of the person you are referring to in order to follow up with them about Axios’ Services.
We may also collect information about you in ways that we explain at the point of collection. You can choose not to provide us with certain types of information, but doing so may affect your ability to use certain Services.

We sometimes get information about you from third-party sources, too. For example:

We may get publicly available information, such as from records published on government websites like a legislative directory.
We may get information from event sponsors you already engage with and who want to ensure you are invited to an Axios event they sponsor.
We may get information from advertisers who want to use Axios to reach their target audiences. For example, an advertiser might provide us, or a trusted intermediary, with a list of people they hope to reach. If they do, we will tell them what percentage of that list matches Axios subscribers without identifying you or any other subscribers. We may then tag matching subscribers as part of a “cohort” group based on interest, industry, or another category to better engage the cohort with our Services. During this process, we do not share Axios subscriber’s emails or other personal information with advertisers.
We may enable third parties to utilize ‘cross-contextual behavioral’, or ‘interest-based’ data to provide targeted advertising on our websites or in our email newsletters. We rely on a number of advertising services to help us provide relevant advertising to you, which may include the use of data these services collect through their relationships with other websites or email engagement activities. You may opt-out of these types of targeted advertisements by following the instructions below. ‍
We may get information from data providers. For example, if you register with Axios, we may ask a data provider to tell us more about you based on the information they’ve collected from other sources. Data providers may give us information like the names, email addresses, phone numbers, addresses, and professional information of people who use, or may be interested in using, Axios’ Services.

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How do we use your personal information?

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Here are some of the key things Axios does with your information:

We use it to provide Axios Services, like sending you newsletters, processing requested transactions, and responding to your inquiries.
We monitor the security of our Services, sometimes with the help of service providers, to help keep the Services and our users safe.
We try to understand how users engage with our Services. For example, we may remove your name and email address from your information and combine it with other users' information to create statistical data about who uses our Services and how. This data helps us answer questions like: “Which articles are users visiting most?” “How do they get to those articles?” “Do users that come directly to our homepage return the next day?” or “What email subject lines get the most opens?” We may engage service providers to help us gather and analyze this data.
We personalize your content and advertising experience on our Services based on a combination of the information you provide to us, the information we or our advertising service providers collect via cookies and similar technologies, and information about you we may get from data providers.
We display ads for our Services and those of our advertising partners. These ads may appear both in the Axios Services and on other websites and platforms through a process known as “targeted advertising,” “cross-contextual behavioral advertising,” or “interest-based advertising”. The delivery and measurement of ads may involve the use of cookies, pixel tags, and other online tracker technologies on our Services.
We measure the impact of ads we display by working with advertising technology companies to track ad placement, views, delivery frequency and efficacy. This helps us answer questions like: “How many users viewed an ad?” “How many times did a user see an ad?” “Did they click on it?” “What do we know about the kinds of users who engaged with the ad?” or “Did our users’ engagement with the ad vary based on where the ad was shown on the site?”
We may email you promotional materials or special offers when you sign up for one of our newsletters. These emails may promote Axios Services, or we may send them on behalf of an advertising partner (we do not share your name or email with the advertising partner when we do this). You can opt out of these messages at any time through the email’s unsubscribe link.
We market Axios Services to you via third-party platforms, including social media platforms. For example: we may use Facebook or LinkedIn advertising tools to help us identify Axios readers who also use those social media services. We could then ask the social media platform to advertise a new newsletter to those readers, or to their other users who might be interested in reading it. Sometimes we do this by uploading a list of subscribers to the third-party platform. Other times, they collect this information directly through our Services using a third-party tracker. You can learn about how to opt-out of this kind of targeted advertising below.
We use marketing surveys to understand our audience and what matters to them. This helps us decide what new areas to report on and what new products or Services to launch. It also helps our advertisers understand who they are reaching when they support us through ad buys or sponsored events. These surveys are voluntary, and you can choose not to participate.
If you log in to Axios with a third-party platform (like Google or Facebook), we may share your information with the platform according to your platform settings.
If you register for an event, Axios uses your registration information to create its guest list and better plan for the event. We may also share this information with the event’s sponsor(s).‍
If you interact with our newsroom over email or by responding to a survey, we may use the information you volunteer to write articles or otherwise inform our reporting. This information is stored separately from other types of user information, and it is not associated with your account for profiling purposes. Your interactions with our newsroom are entirely voluntary.

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How do we share your personal information?

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We may share your information with third parties in the ways described above. This includes sharing with:

Service providers who use it to help us run our business, like the vendors who help us send our newsletters, manage our event registrations, or keep our website secure;
Analytics technology providers who use it to help us understand how people are using our Services so that we can improve them;
Third-party platforms like Facebook, LinkedIn and X, who use it to help us market our Services to you and others like you;
Advertising service providers who help us deliver and provide relevant third-party ads that support our Services financially; and ‍
Event sponsors, who use it to stay in touch with you about their products and services if you registered for their sponsored event.

We may also share your information:

With a payment processor to complete a transaction you initiate, like if you subscribe to Axios Pro, become a Local Member, place a job posting on our job board, or otherwise purchase Services.
As part of a corporate transaction, like a merger or acquisition, or during a bankruptcy.
When required by law, such as in response to a court order, regulatory request, or subpoena.
When we deem it is necessary to protect our employees, our readers, our Services, or our rights under the law or the Terms of Use agreement.
When you specifically allow us to do so by agreeing to the terms we share with you at the point of collection.

You may have the right under applicable law to limit or opt-out of certain types of sharing of your information. You can learn more about that in the Your Privacy Rights section below.

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What else should you know?

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Axios retains your information for the period of time necessary to carry out the business purposes described in this policy unless otherwise required by law. This means we might retain your information even after you unsubscribe from our Services. After we no longer need your data for a specific purpose disclosed above, we will either delete it or de-identify it by removing the information that connects it to you. We may keep de-identified data and use it for statistical purposes.

Axios protects your information using industry-standard organizational, technological and physical safeguards appropriate to our size and the data we process. Unfortunately, nothing on the internet is 100% secure. If you think that your Axios account or any related information may have been compromised, please let us know immediately at privacy@axios.com or support@axios.com.

Axios generally doesn’t want to gather information about you that is considered ‘sensitive’ under U.S. privacy laws, such as government-issued identification (like a passport or social security number), information about your health, biometric data or genetic characteristics, your citizenship or immigration status, or your precise geolocation date.

However, you may choose to voluntarily share certain ‘sensitive’ personal information when you interact with our journalists, respond to our surveys, or participate in our research initiatives**.** This may include information about your race, gender, ethnicity, immigration status, sexuality, health conditions, trade union membership, or religious and political beliefs.
You can always decline to share your ‘sensitive’ personal information with Axios during these interactions or decide not to participate in these interactions at all. If you choose to share your sensitive information with us, we will only use it for journalistic purposes, to improve our Services, or as required by law (unless you give us express permission for other uses).
Axios does not use your sensitive personal information for profiling or marketing purposes. However, please understand that Axios can’t control how third party advertising services may collect or use your information, including information that may be considered ‘sensitive’ under certain U.S. state privacy laws.

Axios does not:

Direct its Services at children under 13 years of age.
Knowingly collect the personal information of minors under the age of 16.
Have actual knowledge that we have sold or shared the personal information of anyone under the age of 16.
Make decisions about you that would produce a legal or similarly significant effect based on profiling.

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Your privacy rights.

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Many U.S. states have privacy laws that create additional data privacy rights for their citizens. This includes states like California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, and others. We call all the states that have privacy laws in effect “Covered Jurisdictions.”

These rights may include the right to:

Notice of our data collection and use practices, including the categories of personal information collected, how the information is used, and to whom it is disclosed. That’s what this Privacy Policy is for.
Access to a copy of the personal information we have collected about you in the past 12 months and information about our use, disclosure, or sale of that personal information.
Correction of any inaccurate information we may have about you.
Deletion of any personal information that we maintain about you (subject to certain legal exceptions).
Opt Out of the sale of your personal information and the sharing of your personal information for ‘cross-contextual behavioral’ or targeted advertising.

State privacy laws may also provide you the right not to receive discriminatory treatment from Axios if you exercise any of your other privacy rights.

Axios will honor your privacy rights if you live in a Covered Jurisdiction. You can learn more about how to make a privacy rights request below.

However, some of the above rights are not absolute. For example:

We may retain your information after you make a deletion request if an exception applies under applicable law.
We may be legally prohibited from providing you with certain sensitive information (like credit card numbers) even if you have a data access right under state law.
We may retain de-identified data derived from your personal information even after a deletion request, so long as it has been modified so that it cannot reasonably be reconnected back to you.

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Submit an access, correction, or deletion request.

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Axios’ Privacy Center allows consumers who reside in Covered Jurisdictions to submit a request to access or delete their personal information, and to manage their consent preferences for sharing their data with third parties.

We will honor requests received from residents of a Covered Jurisdiction.

You will need to provide your email in order for us to take action on your request. Please use the email associated with your Axios newsletter subscriptions. If you have multiple subscriber accounts associated with different email addresses, you may need to submit multiple requests.

We will use our best efforts to fulfill a deletion or access request within 30 days of receipt. We will notify you if we need more time to complete your request.

You will be required to verify your identity before we can fulfill a deletion or access request. We will do this over email. Your request will be denied if you do not respond to our verification email.

We’ll let you know if we deny your request for any reason. We will not penalize you for making a request.

If we deny your request, you can appeal this denial by emailing privacy@axios.com with the subject line: “Appeal for Privacy Rights Request.”
If your appeal is denied and you believe this denial is in error, you may be able to file a complaint with your state’s Attorney General.

Click HERE to view the metrics for consumer privacy rights requests processed by Axios during the 12 month period from the “last updated” date above.

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Opting out of targeted advertising and cross-site marketing.

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Axios does not sell your personal information to third parties for monetary value.

However, in some U.S. states, the use of online tracking technologies for advertising can be considered a “sale” or “sharing” of personal information.

You can opt out of the use of your personal data used for targeted or cross-contextual behavioral advertising in the following ways:

The “Your Privacy Choices'' link. The “Your Privacy Choices” link in our website footer allows you to toggle off “data sales and sharing.” This will set a “flag” in your browser profile to block advertising trackers from activating or “firing” while you are on our site. Be aware that the opt-out flag is itself a first-party cookie within your browser profile. This means you will need to opt-out again if you visit our Services using a different browser or if you clear your browser cookies.
The GLOBAL PRIVACY CONTROL Setting. We also accept the Global Privacy Control ("GPC") signal. To use the GPC, you can download a browser with built-in GPC (like Firefox or Brave) or install a browser plugin (like Privacy Badger). If we detect the GPC signal from your browser, we will automatically block targeted advertising trackers from firing in your browser. But, be aware that certain browser plugins may accidentally block certain functional cookies and cause the Services to not work correctly.
The Privacy Center. Axios sometimes discloses subscriber information to third parties to help us provide you with relevant advertising or market our services through external services such as LinkedIn. If you don’t want us to use your personal information in this way, visit the Privacy Center and choose the “Manage Consent Preferences” tile. You will be asked to verify your email address so we can flag your account as opted-out for this kind of data sharing. You should opt-out using every email address associated with your Axios newsletter subscriptions of Axios Subscriber Accounts. Be aware: You will still need to opt-out of targeted advertising at the browser level (using the Your Privacy Choices link or GPC) if you don’t want targeted advertising trackers to fire on your browser.

You will still see ads on our Services even after opting out of data sales, sharing and targeted advertising. They just won’t be personalized to you based on cross-contextual behavioral data. We do not offer an ad-free experience at this time.

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Remember, you have choices.

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You can opt out of any Axios newsletter by clicking “Unsubscribe” at the bottom of the email. Be aware that we can still send you transactional emails (like purchase confirmations or help ticket replies) even after you unsubscribe.
You can use the Your Privacy Choices link to block targeted advertising Cookies from firing in your current browser profile (until you clear your cookies).
You can use the Global Privacy Control (GPC) to automatically opt out of interest-based advertising across all websites that acknowledge the GPC signal, even after you clear your cookies.
You can use the Privacy Center to flag your Subscriber Account as opted-out of third-party data sharing for marketing purposes.
You can change your browser settings or use a browser plugin to reject cookies and other tracker technologies. However, if you do, the Axios Services may not function properly.
You can use industry opt-out tools to limit use of your information in interest-based advertising by visiting the Digital Advertising Alliance or Network Advertising Initiative websites.

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The bottom line.

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Axios uses your personal information:

To deliver, improve, monitor, and market Axios’ Services;
To provide advertising services to the sponsors who support our journalism; and
In other ways that we make clear to you at the point of collection.

You have choices about how we use your information in some contexts. You can:

Manage your newsletter subscriptions in your Axios Subscriber Account.
Unsubscribe to a newsletter using the unsubscribe link in the email the footer.
Block advertising cookies on our site via the Your Privacy Choices link at the footer of our website.
Download the GPC to block advertising trackers across all the sites you visit.
Use the Privacy Center to manage your consent preference, or request access or deletion of your information.

If you have any questions about this Privacy Policy or about how Axios uses your information, you can email us at privacy@axios.com, and we will do our best to help you. You can also reach us by mail at: Axios Media Inc., PO Box 101060, Arlington, VA 22201.

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RIVER (DNNR.io) Privacy Policy

Privacy for River Platform Company · Last updated Oct 8, 2024

At River, we take your privacy seriously. Please read this Privacy Policy (this “Policy”) to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.

Remember that your use of River’s Services is at all times subject to our Terms of Use, and/or our Creator Terms and Conditions, as each may apply to you, and which incorporate this Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use or Creator Terms and Conditions.

As we continually work to improve our Services, we may need to change this Policy from time to time. We will alert you of material changes by placing a notice on the River website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Policy have been posted, that means you agree to all of the changes.

What this Privacy Policy Covers

This Policy covers how we treat Personal Data that we gather when you access or use our Services or visit our website to contact us for more information to apply for available jobs. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage. If you are a data subject that is a customer of one of our Customers who serves as controller of your Personal Data with respect to use of that data through our Services, please contact that entity regarding sharing of your Personal Data.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

| Category of Personal Data (and Examples) | Business or Commercial Purpose(s) for Collection | Categories of Third Parties With Whom We Disclose this Personal Data | | ----- | ----- | ----- | | Profile or Contact Data (e.g., first and last name, email, phone number, and unique identifiers) | Providing the Services, Marketing the Services, Corresponding with You | Service Providers, Business Partners | | Payment Data (e.g., financial account information, payment card type, last 4 digits of payment card, and billing address, phone number, and email) | Providing the Services | Service Providers (specifically our payment processing partner, currently Stripe, Inc.) | | Commercial Data (e.g., purchase history and consumer profiles) | Providing, Customizing and Improving the Services | N/A | | Device/IP Data (e.g., IP address, device ID, domain server, type of device/ operating system/ browser used to access the Services) | Providing, Customizing and Improving the Services | Service Providers |

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services

Creating and managing your account or other user profiles.
Processing orders or other transactions; billing.
Providing you with the products, services or information you request.
Providing support and assistance for the Services.
Improving the Services, including testing, research, internal analytics and product development.
Personalizing the Services, website content and communications based on your preferences.
Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
We do not use Google user data for any purposes other than providing and improving the Services.

Marketing the Services

Marketing and selling the Services.

Corresponding with You

Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about River or the Services.
Sending emails and other communications according to your preferences or when you apply for jobs with us.

Other Permitted Purposes for Processing Personal Data

In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, River or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

When you provide such information directly to us.
When you create an account or use our interactive tools and Services.
When you send us an email or otherwise contact us.

Third Parties (Vendors)

We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
We may use vendors to obtain information to generate leads and create user profiles.

Third Parties (Social Media Networks)

When you use third party credentials to log into the Services.
We collect and use Google user data solely to provide and improve the functionality of our application.

How We Disclose Your Personal Data

We disclose your Personal Data (except Google user data which is used solely to provide and improve the functionality of our application) to the categories of service providers and other parties listed in this section.

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

Hosting, technology and communication providers.
Analytics providers.
Support and customer service vendors.
Product fulfilment and delivery partners.
We do not disclose Google user data to Service Providers except as necessary to provide or improve our application’s functionality.

Payment processors. Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-provided payment card information necessary to process your payment. Please see Stripe’s terms of service and privacy policy for information on its use and storage of your Personal Data.

Parties You Authorize, Access, or Authenticate. These are parties that integrate with the Services to provide certain features or functionality, such as social media services used for log-ins.

Business Partners. These parties partner with us in offering various parts of the Services. They include Creators whose communities you are part of on the Platform, and whose events you may engage with and attend or host.

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.

Tracking Tools, Advertising, and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services.

We do not use Google user data for advertising purposes or for any purposes prohibited by Google’s policies.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

We retain your profile information and credentials for as long as you have an account with us.
We retain your payment data for as long as we need to process your purchase or subscription.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at help@getriver.io.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at help@getriver.io.

Access

You have the right to request certain information about our collection and use of your Personal Data. In response, we will provide you with the following information in the past 12 months:

The categories of Personal Data that we have collected about you.
The categories of sources from which that Personal Data was collected.
The business or commercial purpose for collecting or selling your Personal Data.
The categories of third parties with whom we have shared your Personal Data.
The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

You may request the above information beyond the 12-month period, but no earlier than January 1, 2022. If you do make such a request, we are required to provide that information unless doing so proves impossible or would involve disproportionate effort.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Personal Data Sales and Shares Opt-Out

In this section, we use the term ‘sell’ and ‘share’ as it is defined in the CCPA. We sell and/or share your Personal Data, subject to your right to opt-out as described in this section.

As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, disclosing your data through third party Cookies for online advertising may be considered “selling” or “sharing” of information. You can opt out by following the instructions in this section.

We sell or share Personal Data, excluding any data obtained through Google OAuth or any other Google services, to the following categories of third parties:

Business Partners comprising of Creators whose communities you are a part of, who purchase subscriptions to the Platform and receive email addresses of community members using the Services.

Over the past 12 months, we have sold or shared the following categories of your Personal Data to categories of third parties listed above:

Profile and Contact Data (excluding Google user data)

We have sold or shared the foregoing categories of Personal Data for the following business or commercial purposes:

Improving the Services, including testing, research, internal analytics and product development.
Personalizing the Services, website content and communications based on your preferences.
Marketing and selling the Services.

You have the right to opt-out of the sale or share of your Personal Data by following the instructions in the “Exercising Your Rights under State Privacy Laws” section. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.

We do not sell or share Google user data with third parties for purposes other than providing or improving our application’s functionality.

To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.

Limit the Use of Sensitive Personal Information

Consumers have certain rights over the processing of their Sensitive Personal Information. However, we do not collect Sensitive Personal Information.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.

Colorado Resident Rights

If you are a Colorado resident, you have the rights set forth under the Colorado Privacy Act (“CPA”). Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Colorado resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at help@getriver.io.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access and request a copy of your Personal Data in a machine-readable format, to the extent technically feasible, twice within a calendar year.

Correction

You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.

Deletion

You have the right to delete Personal Data concerning you.

Personal Data Sales and Targeted Advertising Opt-Out

In this section, we use the term ‘sell’ as it is defined in the CPA. We sell and process for the purposes of targeted advertising your Personal Data, subject to your right to opt-out of these sales.

We sell and process for the purposes of targeted advertising your Personal Data to the following categories of third parties:

Business Partners comprising of Creators whose communities you are a part of, who purchase subscriptions to the Platform and receive email addresses of community members using the Services.

We sell and process for the purposes of targeted advertising the following categories of your Personal Data to categories of third parties listed above:

Profile or Contact Data (excluding Google user data)

We have sold the foregoing categories of Personal Data for the following business or commercial purposes:

Improving the Services, including testing, research, internal analytics and product development.
Personalizing the Services, website content and communications based on your preferences.
Marketing and selling the Services.

You have the right to opt-out of the sale or processing for the purposes of targeted advertising of Personal Data by following the instructions in the “Exercising Your Rights” section.

We do not sell or process Google user data for targeted advertising or any other purposes prohibited by Google’s policies.

Profiling Opt-Out

We do not process your Personal Data for ‘Profiling’ to make ‘Decisions’ under the CPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual’s economic situation, health, personal preferences, interests, reliability, behavior, location or movements. ‘Decision’ means any ‘Decisions that Produce Legal or Similarly Significant Effects Concerning a Consumer,’ as defined in the CPA that concern you.

Connecticut Resident Rights

If you are a Connecticut resident, you have the rights set forth under the Connecticut Data Privacy Act (“CTDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Connecticut resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at help@getriver.io.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

Correction

Deletion

You have the right to delete Personal Data you have provided to us or we have obtained about you.

Portability

You have the right to request a copy of your Personal Data that is processed automatically in a machine-readable format, to the extent technically feasible.

Personal Data Sales and Targeted Advertising Opt-Out

In this section, we use the term ‘sell’ as it is defined in the CTDPA. We sell and process for the purposes of targeted advertising your Personal Data, subject to your right to opt-out of these sales.

We sell and process for the purposes of targeted advertising your Personal Data to the following categories of third parties:

Business Partners comprising of Creators whose communities you are a part of, who purchase subscriptions to the Platform and receive email addresses of community members using the Services.

We sell and process for the purposes of targeted advertising the following categories of your Personal Data to categories of third parties listed above:

Profile or Contact Data (excluding Google user data)

We have sold the foregoing categories of Personal Data for the following business or commercial purposes:

Improving the Services, including testing, research, internal analytics and product development.
Personalizing the Services, website content and communications based on your preferences.
Marketing and selling the Services.

You can opt out from these “sales” by following the instructions in the “Exercising Your Rights under State Privacy Laws” section.

We do not sell or process Google user data for targeted advertising or any other purposes prohibited by Google’s policies.

We Will Not Discriminate Against You for Exercising Your Rights Under the CTDPA

We will not discriminate against you for exercising your rights under the CTDPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CTDPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CTDPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Utah Resident Rights

If you are a Utah resident, you have the rights set forth under the Utah Consumer Privacy Act (“UCPA”). Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Utah resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at help@getriver.io.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

Portability

You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

Deletion

You have the right to delete Personal Data that you have provided to us.

Opt-Out of Certain Processing Activities

Sale of Personal Data: You have the right to opt-out to the sale of your Personal Data. UCPA defines sale as the exchange of Personal Data for monetary consideration to a third party. We sell your Personal Data (excluding Google user data) to Business Partners you have expressed an interest in through the Services, in the form of sharing your Personal Data with them as part of a subscription fee they pay to our Platform. You can opt out this processing of your Personal Data by following the instructions under the “Exercising Your Rights under the State Privacy Laws” Section.

Processing of Sensitive Personal Data: You have the right to opt-out to the processing of your Sensitive Personal Data. We do not process Sensitive Personal Data.

We Will Not Discriminate Against You for Exercising Your Rights Under the UCPA

We will not discriminate against you for exercising your rights under the UCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the UCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the UCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Virginia Resident Rights

If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act (“VCDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Virginia resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at help@getriver.io.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

Correction

Portability

You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

Deletion

You have the right to delete Personal Data you have provided to us or we have obtained about you.

Opt-Out of Certain Processing Activities

You have the right to opt-out to the sale of your Personal Data. We sell your Personal Data to Business Partners you have expressed an interest in through the Services, in the form of sharing your Personal Data with them as part of a subscription fee they pay to our Platform.

To exercise any of your rights for these certain processing activities, please follow the instructions under the “Exercising Your Rights under State Privacy Laws” section.

We Will Not Discriminate Against You for Exercising Your Rights Under the VCDPA

We will not discriminate against you for exercising your rights under the VCDPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the VCDPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the VCDPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Exercising Your Rights under the State Privacy Laws

To exercise the rights described in this Privacy Policy, you or, if you are a California, Colorado or Connecticut resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

Request to Opt-Out of Sale, Share, and/or Targeted Advertising

If you are a California, Colorado, Connecticut, Virginia, or Utah resident, you may opt-out from any “sales,” “shares,” or targeted advertising, by using the following method:

Email us at help@getriver.io.

Request to Access, Delete, or Correct

You may submit a Valid Request for any other rights afforded to you in this Privacy Policy by using the following methods:

Email us at: help@getriver.io

If you are a California, Colorado or Connecticut resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Appealing a Denial

If you are a Colorado, Connecticut, or Virginia resident and we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the CPA, CTDPA, or VCDPA (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by the following methods:

Email us at: help@getriver.io (title must include “[STATE OF RESIDENCE] Appeal”)

If we deny your appeal, you have the right to contact the Attorney General of your State, including by the following links: www.oag.state.va.us/consumer-protection/index.php/file-a-complaint (VA), www.coag.gov/resources/colorado-privacy-act/ (CO), and www.portal.ct.gov/AG/Sections/Privacy/The-Privacy-and-Data-Security-Department (CT).

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at help@getriver.io.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties; in order to submit such a request, please contact us at help@getriver.io.

European Union, United Kingdom, and Switzerland Data Subject Rights

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. River will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at help@getriver.io. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

Profile or contact data
Payments Data

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:

Social network data
Consumer profiles
Web analytics
Commercial history
Geolocation data

We may also de-identify or anonymize Personal Data to further our legitimate interests.

Examples of these legitimate interests include (as described in more detail above):

Providing, customizing and improving the Services.
Marketing the Services.
Corresponding with you.
Meeting legal requirements and enforcing legal terms.
Completing corporate transactions.

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Disclosing Personal Data

The “How We Disclose Your Personal Data” section above details how we disclose your Personal Data with third parties.

EU, UK and Swiss Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at help@river.io. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about River’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through River and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to River in the U.S. and will be hosted on U.S. servers, and you authorize River to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S.

General Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: help@getriver.io

Additional Information

If you would like to opt-out of sharing any of your personal information you can update your profile or contact us at: help@getriver.io