Privacy Policy

1. Personal Information we collect. In this Policy, “Personal Information” means any information relating to an identified or identifiable natural person. We collect Personal Information about you, either directly from you (e.g., when you register an account) or indirectly through automated methods (e.g., via cookies) as listed below.Where applicable, we indicate in this Policy if and why we need you to provide us with your Personal Information and the consequences if you choose not to provide your Personal Information. For example, you may not be able to benefit from our Services if that Personal Information is necessary to provide you with such Services or if we are legally required to collect it.
   • Personal Information provided by you.
   • Business contact information.We may receive professional contact details of employees and other individuals associated with our customers, partners and vendors, such as first and last name, email address, phone number, title and department, and other Personal Information relevant to the particular business relationship.
   • Account information.When you register for our Services, we collect your first and last name, user name, profile picture, password and email address.
   • Communication with ROW Oregon.When you contact us via a contact form or via email, you may provide us with your name, email address, phone number, mailing address, company, title or role and the contents and nature of your correspondence with us.
   • In-Platform communication.If you have a registered account, you can also send messages through, and post comments on, our Platforms. When you do so, we collect the Personal Information you choose to provide us, such as your contact details, any images you choose to upload and the contents and nature of your message.
   • Notifications and marketing messages.When you sign up to receive notifications or marketing from us, you may provide us with your name, email address, company and title/role, depending on the sign-up form that you use (e.g., for product updates, community announcements, newsletters).
   • Personal Information we collect from other sources.Additionally, we may receive Information about you from other third parties whom you have authorized to share your Information or who collect your Information in connection with co-branded offerings.
   • Investors.We may collect, use, and share information from and about investors as described throughout this Privacy Policy, as well as in connection with an investment-related transaction with investors or others, which may include the disclosure of information about investors to third parties to facilitate the implementation, administration and management of such transaction.
     
2. How we use your Personal Information.The main purpose for which we use your Information is to provide you with our Services and to improve your customer experience.We use your information for the following purposes:
   • Services. We use Personal Information to provide, maintain and improve our Services and to provide and deliver our Services to you, including processing transactions.
   • Communicating with you. We use your contact details to contact you for administrative purposes (e.g., to send you confirmations, invoices, technical notices, updates and security alerts, to provide customer services and information that you request or to respond to comments and questions) or to follow up with you if you have indicated an interest in our products, services or business
   • Marketing and interest-based advertising .We will send you updates about our Services, offers, promotions and events offered by RowOregon, and provide you information about topics or content that we think will be of interest to you with your prior consent. Additionally, we and our advertising partners may use cookies and similar technologies to serve interest-based online ads. Please view “How we use cookies and similar technologies” below for more information.
   • Analytics, benchmarking and product development.We and our service providers use Personal Information, such as your interactions with our Services (including Personal Information collected via automated means), to perform benchmarking, to monitor and analyze usage of our Services, and to improve and enhance them.
     
3. How we use cookies and similar technologies. A “cookie” is a small text file that is placed onto a browser or device to record information related to the use of a device or a website. A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. We and third parties automatically collect the following Personal Information via cookies, web beacons and/or similar technologies (collectively “cookies”) in your browser and in emails sent to you:
   • Information about your use of the Platforms. Including when and how many times you access our Platforms, pages viewed, and the page you visited before navigating to our Platforms.
   • Device Information. Including the hardware model, operating system and version of the device that you use to access the Platforms, unique device identifiers and IP address.Below is an overview of the types of cookies we use:
   • Strictly necessary cookies. These cookies allow core website functionality such as user login and account management. Our relevant Services cannot function properly without these cookies.
   • Performance cookies. These cookies, also known as “analytics cookies,” track how visitors interact with our Services and allow us to improve our Services. We may use our own analytics cookies or use cookies offered by our third-party service providers, such as Google Analytics, that collect and process Personal Information on our behalf. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/.
   • Functional cookies. We use these cookies to remember user preferences, e.g., language, timezone, and enhanced content, which allows us to personalize your experience with our Services.
   • Targeting cookies. We and certain third parties, such as content providers and banner networks, use these cookies to track activity of users of our Services over time and across the web. The cookies allow companies to engage in interest-based advertising, as described above.For a current, complete list of all cookies on our website, please visit the cookie preferences section of our cookie banner, where you can manage your cookie preferences in accordance with the categories listed above. Further, many web browsers allow you to manage your preferences relating to cookies. You can set your browser to refuse cookies or delete certain cookies. Please view our Online Tracking Opt Out Guide below for more information.
     
4. How we share your Personal Information. We may disclose Personal Information to third parties if you consent to us doing so, as well as in the following circumstances:
   • Service providers.We work with third party service providers to operate our Services, IT-hosting and maintenance, marketing, accounting and other services for us (e.g. Marketo). These third parties may have access to or process your Personal Information as part of providing those services for us.
   • Advertising partners.Third-party advertising companies may process your Personal Information for the interest-based advertising purposes described in this Privacy Policy.
   • Legal.We may disclose your Personal Information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, or otherwise in cooperation with law enforcement or other governmental agencies.We also reserve the right to disclose your Personal Information that we believe, in good faith, is appropriate or necessary to (i) guard against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our Services and any facilities or equipment used to make our Services available, or (v) protect our property or other legal rights, including to enforce our agreements, or the rights, property, or safety of others.
   • Merger or other corporate transactions.Information about our users, including Personal Information, may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
   • Aggregated and de-identified Information.We aggregate and de-identify your Personal Information so that the information no longer relates to you individually. We may use and disclose aggregated and de-identified data to third parties for a lawful purpose (such as to conduct research collaborations on data usage patterns with universities or to share Platform usage patterns or statistics with customers or business partners).
5. How long we retain your Personal Information.We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period.When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
   
6. How we transfer your Personal Information.We transfer your Personal Information to countries other than the country where you are located, including to the United States or any other country in which we or our service providers maintain facilities.
   
7. Privacy Shield Framework.
   • ROW Oregon complies with the U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information (as defined under the Privacy Shield Principles).
     
8. How we secure your Information.We take appropriate security measures on both a technical and an organisational level, designed to keep your Personal Information secure. Our technical, administrative and physical procedures are designed to protect Personal Information from loss, theft, misuse and accidental, unlawful or unauthorized access, disclosure, alteration, use and destruction. The transmission of data via the internet is not completely secure, and we cannot guarantee the security of your information.You also share responsibility for maintaining the privacy and security of your Personal Information, for example, by not allowing any third party to use your personal account to the Services and avoiding all other non-authorized access to your login and access code.
   
9. Your rights.
   • Marketing opt out.
   • You can unsubscribe from our marketing communications at any time by following the instructions contained within such communications, but you may still receive administrative messages from us regarding our Services.
   • You can limit the use of cookies and other tracking technologies using the cookie preference tool within our cookie banner found at the bottom left-hand side of our website or via the instructions found in the Online Tracking Opt Out Guide below. 
   • California Privacy Rights.If you are a California resident, please review our California Resident Privacy Notice.
     
10. Third-party sites.Our Services may contain features or links to websites and services provided by third parties. Any information you provide on third-party websites or services is provided directly to the operators of such websites or services and is subject to those operators’ policies governing privacy and security, even if accessed via our Services. We are not responsible for the content or privacy and security practices and policies of third parties to which are linked through our Services. We encourage you to consult the third parties’ privacy and security policies to learn more about how they collect and use your Personal Information.
    
11. Changes to this Policy.We may update this Policy to reflect changes in our privacy practices. If we update this Policy, we will make it available through the Services, and indicate the date of the latest revision at the top of this Policy. If we materially change how we use or share Personal Information previously collected from you through the Services, we will notify you through the Services, by email, or other communication, as appropriate.
    
12. Contact Us.If you have any questions about this Policy, please contact us by email at info@roworegon.com